# THE U.S. PH **AS EOUT OF**  **HCFC S**  **:**

**PROJECTED SERVICING NEEDS IN THE U.S.**  **AI R**  **- CONDITIONING**  **, REFRIGERA** **TION , A**  **ND FIRE** 

**SUPPRESSION SECTOR** **S UPDA** **TED FOR 2015 TO 2025** 

Prepared for U.S. Environmental Protection Agency Office of Air and Radiation Stratospheric Protection Division 1200 Pennsylvania Avenue, NW Washington, DC 20460 Prepared with support from ICF International 1725 Eye Street, NW Washington, DC 20006
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## 2014This draft report estimates the quantity of HCFC - 22 (also recognized by the American Society of Heating

Refrigerating and Air- Conditioning Engineers (ASHRAE) designation, R- 22) , HCFC - 142b, HCFC - 123 and HCFC - 124 needed to service air- conditioning and refrigeration equipment and the anticipated installed base of such equipment beyond 201 5 in the United States. The report also discusses the uses and need for other HCFCs , including HCFC - 123 use in nonresidential fire suppression . This analysis has been developed to inform the allocation of HCFC consumption allowances in 2015 - 2019 . Th is report updates the 2009 version of the report of the same name that was released with the 2009 Final Rule titled “Adjustments to the Allowance System for Controlling HCFC Production, Import, and Export , ” (December 2009, 74 FR 66412). This draft report also builds on the discussion included in the memo to the docket titled “ Analysis of HCFC - 22 Servicing Needs in the U.S. Air Conditioning and Refrigeration Sector: Additional Considerations for Estimating Virgin Demand,” (Adjustment Memo, docket ID # EPA- HQ - OAR2011 - 0354 - 0003). A description of notable updates and additions to the Vintaging Model (the model used to develop the data provided in this report) since the 2009 report can be found in Appendix C of th is document . Question s concerning this report should be directed to:

Elizabeth W hitele y Stratospheric Protection Division U.S. Environmental Protection Agency 1200 Penns yl vania Avenue, N W (6205J) Wa shington, D.C. 20460 1 - 202 - 343 - 9 310 (phone) 1 - 202 - 343 - 2338 (fax) whiteley.elizabeth @epa.gov

# Contents

**Executive Summary ................................**  **................................ ................................**  **................................ ....**  **1 1.**  **Background: The U.S. HCFC Phaseout Schedule ................................**  **................................ .............**  **5** 1.1. Report Objective ................................ ................................ ................................ ........................... 6 **2. Me**  **thodology Overview ................................**  **................................ ................................**  **........................ 8**  **3. Overview of HCFC Use in the United States**  **................................ ................................**  **...................... 9**  3.1. Projected HCFC Servicing Need ................................ ................................ ................................ . 10 3.2. HCFC Use in Refrigeration and Air- Conditioning ................................ ................................ ........ 11 3.3. HCFC Use in Nonresidential Fire Suppression ................................ ................................ ........... 15 **4. Projected HCFC Scenarios**  **................................ ................................**  **................................ ................**  **17** 4.1. HCFC - 22 ................................ ................................ ................................ ................................ ..... 17 4.1.1. HCFC - 22 Equipment Used Beyond 2015 ................................ ................................ ........... 17 4.1.2. Projected HCFC - 22 Servicing Needs ................................ ................................ .................. 18 4.2. HCFC - 123 ................................ ................................ ................................ ................................ ... 19 4.2.1. HCFC - 123 Equipment Used Beyond 2015 ................................ ................................ ......... 19 4.2.2. Projected HCFC - 123 Needs ................................ ................................ ............................... 20 4.3. HCFC - 124 ................................ ................................ ................................ ................................ ... 21 4.3.1. HCFC - 124 Equipment Use Beyond 2015 ................................ ................................ ........... 21 4.3.2. Projected HCFC - 124 Needs ................................ ................................ ............................... 21 4.4. HCFC - 142b ................................ ................................ ................................ ................................ . 22 4.5. HCFC Sources ................................ ................................ ................................ ............................ 22 4.6. Meeting Refrigeration and AC Service Need ................................ ................................ .............. 24 4.6.1. Servicing Need and Recovery Projections for HCFC - 22 ................................ .................... 25 4.6.2. Need and Recovery Projections for HCFC - 123 ................................ ................................ .. 27 4.6.3. Servicing Need and Recovery Projections for HCFC - 124 ................................ .................. 28 4.6.4. Summary

of HCFC - 22, HCFC - 123, and HCFC - 124 Servicing Need and Recovery Projections ................................ ................................ ................................ ................................ ........... 28 4.7. Factors Affecting Projections ................................ ................................ ................................ ...... 30 4.7.1. Transitioning to Alternative Refrigerants ................................ ................................ ............. 30 4.7.2. Recovery and Reuse Practices ................................ ................................ ........................... 31 4.7.3. Recycling, Reuse, and Managing Inventory ................................ ................................ ....... 32 4.7.4. HCFC - 22 Economics ................................ ................................ ................................ .......... 32 4.7.5. Increasing Seasonal Energy Efficiency Ratio (SEER) ................................ ........................ 33 4.7.6. Lower Loss Rates ................................ ................................ ................................ ................ 33 **5. C**  **onclusion ................................**  **................................ ................................**  **................................ ..........**  **34 Ap**  **pendix A : Methodology Used to Calculate Projected Servicing Needs**  **................................ .........**  **36 Ap**  **pendix B: HCFC Projections by End -**  **Use ................................**  **................................ ..........................**  **46 Ap**  **pendix C: Changes to the Vintaging Model ................................**  **................................ .......................**  **48 Ap**  **pendix D: Sensitivity Analyses ................................**  **................................ ................................**  **........... 49**  **Ap pendix E: HCFC**  **- 22 Inventory Estimate**  **................................ ................................**  **.............................. 54**  **References ................................**  **................................ ................................**  **................................ .................**  **55**The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 1 

# Executi **ve Summary**  Hydrochlorofluorocarbons (HCFCs) are a class of chemical compounds that deplete the stratospheric ozone layer, increasing the chances of overexposure to ultraviolet (UV) radiation at the earth’s surface. Excessive UV radiation damages biological systems and causes malignant melanoma and other skin cancers, cataracts and other eye damage , and harm to certain crops a nd marine organisms. Reversing the course of stratospheric ozone depletion is crucial to human and environmental health worldwide. As a Party to the Montreal Protocol on Substances that Deplete the Ozone Layer (Montreal Protocol), the United States is subj ect to a cap on HCFC consumption —defined as production 1 plus imports minus exports— in an international effort to protect the stratospheric ozone layer (UNEP 2000). Specifically, the United States is obligated to phase out production and consumption of HCFC s by 2030 by making graduated reductions in HCFC production and consumption by certain dates. To meet these interim reduction targets, the U.S. Environmental Protection Agency (EPA) established a schedule for the phaseout of HCFCs. EPA phased out consumption of HCFC - 141b in 2003. On January 1, 2010, the production and import of HCFC - 142b and HCFC - 2 2 were banned except for servicing equipment manufactured before January 1, 2010. The next phaseout milestone will occur in 2015 with a ban on production and im port of any other HCFCs , except for use as refrigerants in equipment ma nufactured prior to Janua ry 1, 2020. In addition, in December 2011, Title VI of the Clean Air Act was am ended to permit the use of HCFCs in non - residential fire suppression applications. Starting on January 1, 2020, there will be a ban on any remaining production and import of HCF C - 22 and HCFC - 142b , 2 and production and import of other remaining HCFCs will be limited to use as a refrigerant to service existing equipment. Thus, starting in 2015, the production and im port of virgin HCFCs in the United States will be limited to servicing existing refrigeration and AC equipment , and non - residential fire suppression applications . 3 Historically, only HCFC - 22, HCFC - 142b, HCFC - 123, and HCFC - 124 have been used in significant quantities in these applications. Table ES 1 presents an overview of the use limitations, applications, and servicing need projections for these four HCFCs . **ES 1**  **: Overview of HCFC Use Limitations, A**  **pplicat ions, and Projections for 2015 to 2025**  **HCFC Regulatory**  **Limitations Applications**  **Is Servicing Need**  **Projected for 2015**  **- 2025?**  **Ref/ AC Non**  ****

**Residential Fire**  **Suppression** HCFC 22 Production and import limited January 1, 2010

to use as a refrigerant in, or to provide service to, appliances manufactured prior to January 1, 2010.  -- Yes . HCFC 142b  -- No t in the Vintaging Model . HCFC 142b is a component of certain blend s that have limited refrigeration applications , some of which (e.g., R409A) are not modeled. HCFC 123 Production and import will be limited beginning

January 1, 2015, to use as a refrigerant in, or to provide service to, appliances manufactured prior to January 1, 2020. HCFC 123 and HCFC - 124 can also be produced and imported for use as a nonresidential fire suppress ant until 2020.   * Yes . HCFC 124  -- Yes. In addition , HCFC - 1 24 is a component of certain blend s that have limited refrigeration applications , some of which (e.g., R-409A) are not modeled. * HCFC - 123 is a constituent of the Halotron I blend used in fire applications . 1 Under the Montreal Protocol, production is defined as “the amount of controlled substances produced, minus the amount destroyed...and minus the amount entirely us ed as feedstock in the manufacture of other chemicals. The amount recycled and reused is not to be considered as production” (UNEP 2000). 2 Exceptions to this ban include the use of HCFC - 22 or HCFC - 142b in: 1) processes resulting in their transformation or destruction or 2) pre - authorized importation of recovered, reclaimed, or recycled HCFCs. 3 The Clean Air Act allows for the continued use of “used, recovered and recycled” HCFCs.The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 2 Table ES 2 presents the Vintaging Model’s projected servicing need for HCFC - 22, HCFC - 142b, HCFC 123, and HCFC - 124 in refrigeration, air conditioning, and non - residential fire suppression applications. As noted above, although the Vintaging Model projects no servicing need for HCFC - 142b and minimal servicing need for HCFC - 124 between 2015 and 2025 , other information —such as refrigerant sales data collected by the California Air Resources Board —suggests th at HCFC - 142b and HCFC - 124 are still in use in niche refrigeration applications . **Table ES 2**  **: Projected HCFC**  **- 22, HCFC**  **- 142b, HCFC**  **- 123, and HCFC**  **- 124**  **Servicing Need for**  **Refrigeration, A ir** **- Conditioning, and Fire Suppression, 2015**  **- 2025**  **(Metric Tons) HCFC**  **2015 2016**  **2017 2018**  **2019 2020**  **2025** HCFC - 22 46,100 41,600 36,700 32,300 27,700 22,500 5,500 HCFC - 142b - - - - - - - HCFC - 123 2,200 2,200 2,200 2,300 2,300 8 00 7 00 HCFC - 124 4 4 4 4 4 4 - Source: Vintaging Model (20 12). Although limited production and consumption of virgin HCFC - 22 and HCFC 142b can be allowed until 2020 , and HCFC - 123 and HCFC - 124 production can be allowed until 20 3 0 (HCFC - 22 , HCFC - 142b ) , 4 with industry effort, a significant portion of the need for HCFC s for servicing is expected to be me t with previously used refrigerant that is recovered and then recycled or reclaimed. To determine the potential am ounts of used refrigerant available to service equipment, EPA used its Vintaging Model to develop three scena rios of recovery to estimate: 1) the projected amount of recovered HCFCs potentially available to meet servicing need of equipment still in use; and 2) the subsequent quantity of HCFCs needed to satisfy the re ma ining need . Scenarios based on the Vintaging Model were not developed for HCFC - 142b. Figure ES - 1, Figure ES - 2, and Figure ES - 3 present the results of these lower, baseline , and higher HCFC recovery scenarios. For HCFC - 22 , the lower recovery scenario ass um es that 35 percent of HCFC - 22 from retired or retrofitted equipment is recovered and available for reuse in equipment ; 5 the baseline scenario assumes a recovery rate that is equal to the rate that is modeled by EPA’s Vintaging Model; 6 and the higher reco very scenario assumes 65 percent recovery. For HCFC 123 and HCFC - 124 , the recovery rate mo deled by the Vintaging Model is used for all three scenarios, since it is significantly higher (approximately 80 to 9 0 percent ). In accordance with U.S. commitments under the Montreal Protocol, HCFC consumption (i.e., production and imports of virgin HCFCs) cannot exceed 1,524 ODP - weighted metric tons from 2015 to 2019 and cannot exceed 76.2 ODP - weighted me tric tons starting in 2020 . Figures ES - 1 through ES - 3 summari ze servicing need in comparison to th is U.S. HCFC consumption cap . T he figures also present the amount of need that can be met by recovered and reused ma terial (dark grey) and the remaining amount that would need to be met by virgin material .

4 New production and import of HCFC - 22 for servicing is possible until January 1, 2020. While EPA has not proposed allowances for HCFC - 123 after 2019, EPA is considering allowing new production and import for servicing up until January 1, 2030. 5 The remaining 65% is not available for reuse. 6 Varies by end - use but in total e quals about 50% industry-wide for the time period considered. **Box ES -**  **1: Sensitivity A nalysis**  While EPA’s assumptions are frequent ly updated to refine assumptions, the projections of future servicing needs for HCFC - 22 can be affected by outside factors that are not fully reflected in the estimates. A sensitivity analysis performed on key modeling assumptions suggests that HCFC - 22 servicing demand could be marginally to significantly lower than what is projected. In particular, servicing nee d may be lower if the system charge size, leak rate, and/or equipment lifetime are less than current assumptions. The projections in this report provide only some of the information necessary for determining post- 2015 servicing needs.The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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**Fi gure ES**  **1 :**  **Total Projected HCFC Demand, Lower Recovery Scenario** 

**Figure ES 2**  **: Total Projected HCFC Demand,**  **Baseline Recovery Scenario**The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 4 The analysis demonstrates that it is possible to meet the projected servicing and new equipment needs 7 for HCFC - 22 , HCFC - 123 , and HCFC - 124 in 2015 under the baseline and higher recovery scenarios (see Figure ES - 2 and Figure ES - 2 ). R ecovered refrigerant, in addition to lim ited amounts of virgin refrigerant (not exceeding the cap), can satisfy future servicing needs. As shown in Figure ES - 1, the AC and refrigeration industry m ay face potential shortage risks in a lower recovery scenario. Several other factors also influence the level of HCFC servicing need and sufficiency of recovered supply in 2015 and beyond. For example, with approximately 9 7 mi llion AC and refrigeration units projected to be in use in 2015, the sooner consumers transition to equipment using alternative refrigerants, the better the chance for an adequate HCFC - 22 , HCFC - 123 , and HCFC - 124 supply to satisfy the forecasted servicing need . This report explores the following market trends and how they may influence future HCFC servicing nee d and available supply estimates, including: • the rate of market transition to alternative refrigerants in the United States; • HCFC - 2 2 cost; • assumed equipment leak and servicing loss rates; • increased seasonal energy efficiency ratio (SEER) standards; and • quantities of refrigerant recovered for reuse, reclamation, and/or banking. If leak rates, practiced equipment lifetimes, and charge sizes are less than what the agenc y currently assumes—as suggested by some stakeholders—servicing need , as well as necessary virgin supply, could be significantly lower than what is presented in the figures above.

7 Because the Clean Air Act prohibits the use of virgin HCFC - 123 starting in 2020, this report only models new equipment demand for HCFC - 123 for 2015 to 2020.

**Figure ES 3**  **: Total Projected HCFC Demand,**  **Higher Recovery Scenario**The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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# 1. **Background: The U.S. HCFC Phaseout Schedule** Title VI of the 1990 Clean Air Act Amendments (CAAA) mandates the development and implementation of regulations to protect the stratospheric ozone layer and ensure U.S. compliance with the Montreal Protocol on Substances that Deplete the Ozone Layer (the Montreal Protocol) . Under the Montreal Protocol, the United States and other signatories have agreed to achieve progress toward the total phaseout of the consumption and production of HCFCs, which are ozone - depleting substances (ODS) and have been widely used as refrigerants, solvents, foam blowing agents, and fire suppressants. 8 Consumption is defined as production plus imports minus exports; production is defined as the ma nufacture of a controlled substance minus amounts destroyed and amounts completely used as feedstock in the manufacture of other chemicals . Neither consumption n or production include s am ounts that are reused or recycled (UNEP 2000). In September 2007, the nineteenth Meeting of the Parties to the Montreal Protocol was held in Montreal, Canada, marking the 20 th anniversary of the signing of the Protocol . At the meeting, the Parties agreed upon a strengthened phaseout of HCFCs . The adjustments call for non -Article 5 countries—the Protocol’s identifyi ng term for developed countries—to lim it HCFC production and consumption to 25 percent of baseline by 2010, 1 0 percent by 2015, and 0 .5 perc ent by 2020—allowing for 0.5 percent of the baseline for annual servicing over the period 2020 - 2030. 9 Previously, the 2010 reduction step was 65 percent and was limited solely to consumption, not production . Table 1 - 1 presents the HCFC consumption baseline and the graduated reductions (caps) to allowable HCFC consumption for the United States (and all Article 2 countries) . **Table 1**  **- 1**  **: U.S. HCFC Consumption Phaseout**  **Schedule U**  **nder the Montreal Protocol**  **Date Consumption Cap**  **ODP Weighted Metric Tons**  a **Quantity Expressed in**

**HCFC -**  **22 Metric**  **Tons b**  Jan 1, 1996 B aseline set at 2.8 % of the 1989 ODP -weighted

CFC consumption plus 100 % of the 1989 ODP weighted HCFC consumption 15,240 277,091 Jan 1, 2004 35%reduction from the baseline 9,906 180,109 Jan 1, 2010 75%reduction from the baseline 3,810 69,273 Jan 1, 2015 90%reduction from the baseline 1,524 27,709 Jan 1, 2020 99.5% reduction from the baseline 76.2 0 c Jan 1, 2030 100% reduction from the baseline 0 0 aAn O DP -weighted metric ton take s into account each ODS’ relative contribution to ozone depletion . One metric ton equals approximately 2,204 pounds . b Calculated using an ODP of 0.055 for HCFC -22. c In 2020, 0.5 percent of the U.S. consumption baseline remains, but the U.S. phaseout schedule prevents any allocation to HCFC -22 . Table 1 - 2 details the U.S. phaseout schedule for HCFCs established under the 1990 CAAA to comply with the targets set by the Montreal Protocol (as presented in Table 1 - 1) . T he production and import of HCFC - 141b, the HCFC with the highest ODP, was phased out with limited exempti ons on January 1, 2003 . B eginning in 2003, EPA established an allowance system to control the U.S. production and consumption (including import and export) of HCFCs and to apportion consumption allowances amongst HCFCs . Allowance s are the privilege granted to an allowance holder to produce and/or import a limited quantity of an HCFC on an annual basis . Production and consumption allowances for HCFC - 141b (for lim ited exemptions), HCFC - 22, and HCFC - 142b were authorized and distributed (on a kilogram basis) to certain companies (EPA 2003a). 10 In the 2009 HCFC allocation rule , Protection of Stratospheric Ozone: 8 The production and import of othe r ODS used by these industries, including chlorofluorocarbons, carbon tetrachloride, and methyl chloroform, were phased out in 1996 – halons in 1994 (with limited exemptions). 9 Article 5 countries—the Protocol’s identifying term for developing countries— follow a later phaseout schedule than Article 2 countries and as a result of the agreement in 2007 are subject to a freeze in 2013 followed by reduction steps of 10 percent by 2015, 35 percent by 2020, 67.5 percent by 2025, and allowing for servicing at an annual average of 2.5 percent from 2030 - 2040. 10 The production of one kilogram of HCFC requires the expenditure of one production allowance and one consumption allowance. The import of one kilogram of HCFC requires the expenditure of one consumption allowa nce. W hile the import of used HCFCs does not require the expenditure of allowances, it does require petition approval by EPA; see Section 4.2.1 for more detail.The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 6 Adjustments to the Allowance System for Controlling HCFC Production, Import, and Export , EPA authorized and distributed (on a kilogram basis) production a nd consumption allowances for HCFC - 123, HCFC - 124, HCFC - 225ca, and HCFC - 225cb to certain companies in addition to HCFC - 22 and HCFC 142b ( EPA 2009 ) . The 2009 HCFC a llocation r ule was challenged in Arkema v EPA (618 F.3d 1, DC Cir. 2010) and the portion of the rule that establishes company- by- company production and consumption baselines and calendar- year allowances for HCFC - 22 and HCFC - 142b was vacated. All other aspects of the rule are intact. In August 2011, EPA issued an interim final rule that establishe d new company- bycom pany HCFC - 22 and HCFC - 142b baselines and allocate d production and consumption allowances for 2011 (EPA 2011) . In April 201 3 , EPA published a final rule allocating HCFCs for 2012 through 2014. **Table 1**  **- 2**  **: U.S. HCFC Phaseout Schedule**  **as Implemented by EPA Under the 1990 CAAA**  **( To Comply**  **with the Protocol) Date**  **Restriction** Jan 1, 2003  Ban on production and import of HCFC - 141b . Jan 1, 2010  Ban on production and import of HCFC - 22 and HCFC - 142b except for on - going servicing needs

in equipment manufactured before January 1, 2010. a Jan 1, 2015  Ban on the production, import, and introduction into interstate commerce or use of HCFCs

except where the HCFCs are used as a refrigerant in equipment manufactured prior to January 1, 2020 or where HCFCs are used as a fire suppression agent for nonresidential applications . a , b Jan 1, 2020  Ban on remaining production and import of HCFC - 22 and HCFC - 142b. a

 Ban on production and consumption of all other HCFCs except for use in servicing refrigeration and AC equipment produced before January 1, 2020. c Jan 1, 2030  Ban on production and import of all HCFCs. a a Certain additional exemptions apply, including exemptions for (1) HCFCs used in processes resulting in their transformation or destruction, or (2) pre -authorized import of HCFCs that are recovered and either recycled or reclaimed. bTitle VI of the Clean Air Act was amended in December 2011 to allow the continued use of virgin HCFCs for nonresidential fire suppression purposes until January 1, 2020 . cArticle 2F of the Montreal Protocol requires that each Party shall ensure that consumption and production of hydrochlorofluorocarbons does not exceed zero; however, each Party may exceed that limit provided that consumption is restricted to the servicing of refrigeration and AC equipment manufactured before January 1, 2020. Source: EPA (2003a); EPA (2007) ; United States Congress (2011) ; UNEP (2000 ). Effective January 1, 2010, U.S. production and import of HCFC - 22 and HCFC - 142b were limited to use in equipment manufactured prior to January 1, 2010 , with a complete phaseout of these HCFCs by January 1, 2020. 11 In addition to the HCFC - 22 and HCFC - 142b restrictions, b eginning January 1, 2015, U.S. production, import, use, or introduction into interstate commerce of all other HCFCs will be banned except for use as refrigerants in equipment manufactured prior to January 1, 2020 or for use in nonresidential fire suppressi on. Starting in 2020 , the Montreal Protocol further restricts production and import of virgin HCFCs to servic ing of existing AC and refrigeration equipment . A complete ban on production and import of HCFCs goes into effect January 1, 2030 . 12 This report e valuate s the amount of HCFC s ne eded to ensure that the U.S. me ets its international commitment under the Montreal Protocol, while also allowing for equipment owners to service HCFC dependent equipment until the end of its useful life. 

## 1.1. **Report Objective** This report presents quantitative estimates of the projected am ount of (a ) units of equipment using HCFC 22 , HCFC - 142b, HCFC - 123 , and HCFC - 124 beyond 201 5 in the United States and (b) HCFC - 22 , HCFC 142b, HCFC - 123 , and HCFC - 124 needed to me et servicing need beyond 201 5 in the United States. 13 This report is an update to the 2009 report The U.S. Phaseout of HCFCs: Projected Servicing Needs in the U.S. Air

- Conditioning an d Refrigeration Sector that provided projections through 2020. This report

11 Or where additional exemptions apply. 12 HCFCs can also be produced and imported for use as a feedstock. 13 HCFC - 22 and HCFC - 142b are only permitted for servicing existing equipment beyond 2015. HCFC - 123 and HCFC - 124 can be used for servicing or to charge new air- conditioning or refrigeration equipment manufactured before January 1, 2020, or in nonresidential fire suppression applications.The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 7 estimates HCFC consumption needs for air- conditioning (AC) and refrigeration equipment (the largest HCFC market and the largest industry sector using HCFCs) that will be in use after 201 5 and possible future recovery scenarios to help me et those needs . This analysis also explores, in a limited way, servicing need for HCFC s for nonresidential fire suppression applications beyond 2015 . The rem ainder of the report is organized as follows:

 Section 2 provides a brief overview of the methodology used to project servicing scenarios.  Section 3 provides an overview of HCFC use in the United States, including projected servicing need of HCFCs, an overview of HCFC use in the AC and refrigeration sector , and an overview of HCFC use for nonresidential fire suppression .  Section 4 provides t hree projected recovery scenarios and resulting HCFC - 22 , HCFC - 123 , and HCFC - 124 consumption needs . Section 4 also provides some discussion on expected HCFC 142b servicing need based on industry feedback.  Section 5 summarizes factors that may affect the projections presented in the report .  Appendix A presents further information on the projection methodology and its limitations.  Appendix B provides AC and refrigeration projections by end - use.  Appendix C provides an overview of the changes that have been made to EPA’s Vintaging Model s ince the 2009 report The U.S. Phaseout of HCFCs: Projected Serv icin g Needs in the U.S. AirConditioning and Refrigeration Sector (“Servicing Tail Report”).  Appendix D provides sensitivity analyses performed to determine the effect that several key assumptions may

have on HCFC - 22 servicing need . Assumptions considered include: system charge size, average annual equipment leak rates (i.e., loss rates), and the expected length of tim e a system is in opera tion (i.e., equipment lifetime) .The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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# 2. **Methodology Ov** **erv ie** **w** This report provides projections estimating the servicing need for HCFCs for 2015 to 2025. Appendix A discusses the assumptions used to develop the supply and servicing need estimates presented in this report and the limitations and caveats inherent in the analysis. EPA’s Vintaging Model is the primary tool used to perform the analysis and form s the basis for quantitative estimates of current and projected HCFC consumption. The Vintaging Model estimates the annual chemical emissions from industry sectors that have historically used ODS, including AC, refrigeration, foams, solvents, aerosols, and fire protection. Wi thin these industry sectors, there are over 60 independently modeled end - use s. The model uses information on the market size and growth for each end - use, as well as a history and projections of the ma rk et transition from ODS to alternatives. As ODS are phased out, a percentage of the market share originally filled by the ODS is al located to each of its substitutes. The model tracks emissions of annual “vintages” of new equipment that enter into operation by incorpo rating information on estimates of the quantity of equipm ent or products sold, serviced, and retired or retrofitted eac h ye a r, and t he quantity of the c hem ical required to manufacture, charge, and/or maintain the equipment. EPA’s Vintaging Model uses this market information to build an annual inventory of in - use stocks of equipment and the ODS and non - ODS substitutes in ea ch end - use. The model is updated on a regular basis to reflect changes in the ma rk et and new industry information. Updates to the Vintaging Model since the release of the 2009 Servicing Tail Report are summarized in Appendix C. This report provides an upd ate of HCFC - 22 servicing need s for air- conditioning and refrigeration equipment , as well as an update on the estimate d servicing need for other HCFCs. This analysis has undergone many revisions; key milestones include:
 The first release of this report was on November 4, 2005 when EPA made the preliminary draft version available for comment in a Notice of Data Availability (NODA, 70 FR 67172) . Based on comments received from stakeholders , EPA used the Vintaging Model to test whether servicing need mi ght exc eed supply under some circumstances .  On September 29, 2006, EPA’s Stratospheric Protection Division held a meeting for HCFC stakeholders regarding the 2010 milestone in the HCFC phaseout . EPA issued a September 2006 version of this report at that time. Th is version contained one additional scenario of consumption needs for HCFC - 22 based on stakeholder input on the 2005 draft report .  A June 2008 version of the report took into account the comments from stakeholders and provided an updated set of analyses b ased on the most recent Vintaging Model output. The June 2008 version of the report included the HCFC - 22 estimates of a recovery rate of 15, 20, and 75 percent in addition to updating the previous scenarios of 10 and 50 percent.  On December 23, 2008, EPA p ublished two proposed rules, Adjustments to the Allowance System for Controlling HCFC Production, Import, and Export ( 73 FR 78680 ) and Ban on the Sale or Distribution of Pre - charged Appliances (73 FR 78705) . Comments on both proposed rules were submitted d uring the public comment period in early 2009 in Docket ID No. EPA – HQ–OAR–2008–0496 and Docket ID No. EPA – HQ–OAR–2007–0163 respectively. The Allowance System proposed rule requested comments on the draft servicing tail analysis.  In December 2009, another version of the report took into account relevant comments from stakeholders. The report focused on two recovery rates scenarios (20 and 50 percent) and presented the actual allocation amounts for the 2010 - 2014 control periods as found in EPA’s final rule.  In November 2011, EPA conducted research and analysis to account for the changes in the HCFC - 22 market since the 2009 Final Rulemaking. The 2011 memorandum (Docket ID No. EPA- HQ - OAR- 2011 - 0354 - 0003 ) provided additional information on virgin HCFC - 22 inventory , recovery and reuse practices in large retail food, and reclamation trends and capacity. The purpose of the projection s presented in this report and earlier versions is to support the process of allocating HCFC consumption allowances. To that end, this report update focuses on the next segment of ye ars in the phaseout—2015 through 2025 and the four ma in HCFCs of concern — HCFC - 22 HCFC - 123 , HCFC - 124 , and HCFC - 142b .The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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**Box 3**  **- 1**  **: Summary of Co**  **mmon HCFCs and their End -**  **Use Applications** 

###  HCFC- 141b - h istorically used as a blowing agent in rigid polyurethane foams and integral skim foams and in aerosol solvent cleaning applications. Production and consumption phased out in 2003 except for exemption production for specific applications . 

###  HCFC- 22 - used as a refrigerant in several applications such a s unitary air conditioners, cold storage, retail food refrigeration equipment, chillers, and industrial process refrigeration ; see Section 4 for further information. Also used (in smaller quantities) as a blowing agent for certain foam applications and as a component of some sterilant mixtures. Production and consumption phased out in 2010 except for servicing appliances manufactured before Ja nuary 1, 2010. 

###  HCFC- 123 - used in centrifugal chillers and as a blend in portable fire extinguishers. 

###  HCFC- 124 - used in sterilant mixtures and as a component in some replacements for CFCs as a refrigerant or for halon as a fire suppressant . Replaces CFC - 1 14 in some heat pumps and special air conditioning equipment. HCFC 1 2 4 (combined with HCFC - 142b) is also a component of some blends (e.g., R-409A , R-414B ), which are primarily used as a retrofit alternative to CFC - 12 and R- 500 in refrigeration applications . Use of HCFCs as a sterilant is being phased out in 2015 by the Clean Air Act. 

###  HCFC- 142b - historically used as a blowing agent in extruded polystyrene board stock . Also used in small quantities in refrigerant blends as a retrofit refrigerant for applications such as motor vehicle ACs that previously used CFC - 12 and other refrigeration applications that previously used CFC - 12 and R- 500. Production and consumption pha sed out in 2010 except for servicing appliances manufactured before January 1, 2010. 

###  HCFC- 225ca/cb - used as a solvent, an aerosol solvent, and in small quantities in the adhesives, coatings, and inks sector. HCFC - 225 ca/cb is a mixture of the two isomers HCFC - 225ca and HCFC - 225cb typically in a 45/55% by weight ratio. Use of HCFCs as a solvent is being phased out in 2015 by the Clean Air Act.

**Table 3**  **- 1**  **: HCFC Atmospheric Lifetime (Years) and Ozone Depletion**  **Potential HCFC**  **Chemical Name CAS**  **Number Atmospheric** 

**Lifetime (years)**  **ODP** a HCFC - 141b (CH 3 CFCl 2 ) 1,1 - Dichloro - 1 -fluoroethane 1717 - 00 - 6 9.2 0.11 HCFC - 142b (CH 3 CF 2 Cl) 1 - Chloro - 1,1 - difluoroethane 75 - 68 - 3 17.9 0.065 HCFC - 22 (CHF 2 Cl) Chlorodifluoromethane 75 -45 - 6 12.0 0.055 HCFC - 124 (CF 3 CHFCl) 2 - Chloro - 1,1,1,2 -tetrafluoroethane 2837 - 89 - 0 5.8 0.022 HCFC - 123 (CHCl 2 CF 3 ) 1,1 - Dichloro - 2,2,2 -trifluoroethane 306 - 83 - 2 1.3 0.02 HCFC - 225cb (CF 2 ClCF 2 CHClF) 1,1,2,2,3 - pentafluoro - 1,3 - dichloropropane 507 - 55 - 1 2.1 0.033 HCFC - 225ca (CF 3 CF 2 CHCl 2 ) 1,1,1,2,2 - pentafluoro - 3,3 - dichloropropane 422 - 56 - 0 5.8 0.025 a ODP values are taken from the Montreal Protocol (UNEP 2003b). 

# 3. **Ov er** **vi ew** **of HCFC Use in the United States** HCFCs have a variety of applications in the foam, aerosol, solvent cleaning, fire protection , and sterilization industry sectors; however, their largest presence is in the AC and refrigeration industr ies . Although the Montreal Protocol has identified num erous HCFCs under Article 2F, only those listed in Box 3 - 1 have been consumed in significant quantities in the United States. Starting in 2015, use of virgin HCFCs will be limi ted to refrigeration, AC, and nonresidential fire suppression applications.

Section 3 is organized into t hree subsections . Section 3.1 provides a brief discussion of projected servicing need of HCFCs, including estimates in ODP - weighted metric tons. Section 3.2 presents an overview of the HCFC servicing need in the AC and refrigeration sector. Section 3.3 presents an overview of the HCFC servicing need for nonres idential fire suppression .The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 10 

## 3.1. **Projected HCFC Servicing Need**  Servicing need is projected for the following HCFCs: HCFC - 22, HCFC - 142b, HCFC - 123, and HCFC - 124. A n overview of the use limitations, applications, and projected servicing need for these HCFCs is included in Table 3 - 2 . **Table 3**  **- 2**  **: Overview of HCFC Use Limitations, A**  **pplications, and Projections for 2015 to 2025** 

### HCFC **Regulatory Limitations Applications**  **Is Need**  **Projected for 2015**  **- 2025?**  **Notes on Servicing Need** 

**Projections Ref/ AC**  **Non**  

** Residential** **Fire Suppression**  HCFC - 22 Production and import

limited January 1, 2010 to use as a refrigerant in, or to provide service to, appliances manufactured prior to January 1, 2010. 

###  --   Estimated based on EPA’s Vintaging Model HCFC - 142b



###  -- --  For 2015 and beyond, the Vintaging Model projects no HCFC - 142b servicing need , although other data suggests that HCFC - 142b is still in use  HCFC - 142b is a component of some blends (e.g., R409A*), which are primarily used as a retrofit alternative to CFC - 1 2 and R- 500 in refrigeration applications HCFC - 123 Production and import will

be limited beginning January 1, 2015, to use as a refrigerant in, or to provide service to, appliances manufactured prior to January 1, 2020. Virgin HCFC - 123 and HCFC - 124 can also be used for nonresidential fire suppression purposes between 2015 and 2020. 

###     Estimated based on Vintaging Model and other sources  HCFC - 123 is used as a refrigerant and as a constituent of the Halotron I blend used in fire suppression applications HCFC - 124 

###  --   Sterilant use no longer allowed  Projections based on Vintaging Model  HCFC - 124 is used in several SNAP - approved refrigerant blends (e.g., R-401A, R401B, R-409A*, R-414A, R414B, and R-416A) *R-409A is not modeled in the Vintaging Model. Figure 3 - 1 dem onstrates projected HCFC servicing need in 201 5 and 202 0 ; as shown, HCFC - 22 servicing needs constitute over 9 5 % percent of all HCFC servicing need in 201 5 and about 9 7 % of HCFC servicing need in 202 0 .The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 11 **Figure 3**  **- 1**  **: Total Projected HCFC**  **Servicing Need for**  **Refrigeration, A C, and Fire Suppression**  14 **(M etric Tons)** 



## 3.2. **HCFC Use in R** **efrigeration and Air -**  **Conditioning** Historically, CFCs were extensively used as refrigerants in the AC and refrigeration industries; by the 1970s, HCFC - 22 and R- 502 (a blend of CFC - 115 and HCFC - 22) were also well established refrigerants. On January 1, 1996, the production and import of CFC refrigerants, cl assified as Class I controlled (ozone - depleting) substances under th e CAA Am endments of 1990, were phased out in the U.S. and other industrialized countries. HCFC refrigerants, which deplete the ozone layer to a lesser degree and are classi fied as Class II controlled substances under the 1990 CAA A , were found acceptable as substitutes for the controlled CFCs in some end use applications . 

### Air **- Conditioning End** 

**- Uses**  AC equipment can be categorized as either mobile or stationary . Figure 3 - 2 below illustrates these categories and identifies those AC end uses for which supply and servicing need projections are estimated in this report. **M obile air** **- conditioning**  systems include all forms of AC that provide cooling to passenger com partm ents in all types of moving vehicles. This category can be further broken down into motor vehicle air- conditioning for light- duty vehicles and other m obile air- conditioning systems .  Motor vehicle air

- conditioning (MVAC) includes AC in the passenger compartments of light duty vehicles— both cars and trucks ( e.g., pick - up trucks, minivans , sport utility vehicles ). A variety of refrigerant blends, some of them including HCFCs, are approved for use in the United States by EPA as replacements for CFC - 12 in MVACs. However, these blends have not been endorsed by vehicle or system manufacturers for such use, thereby captu ring only a small and declining share of the retrofit market, which consists mainly of HFC - 134a . HFC - 134a is not an ODS; t herefore, the light- duty MVAC sector is not considered further in this analysis .  Other mobile air

- conditioning includes AC in the pas senger compartments of both buses (including school, transit, and tour buses) and trains (including heavy, light, and commuter rail, and Amtrak trains). 15 Although most bus AC systems converted directly from CFC - 12 to HFC 134a , t he majority of the existing fleet of transit buses, tour buses, and trains are projected to continue to use HCFC - 22 in their AC systems .

14 The estimates for fire suppression demand are based on EPA’s Vintaging Model projections assuming no phaseout of HCFCs for fire suppression use between 2015 and 2019. Between 2020 and 2025, HCFC - 123 demand includes both demand for recycled HCFC - 123 to charge new portable fire extinguishers, as well as air conditioning servicing demand. 15 For the purposes of this report, “other mobile AC” does not include ships, planes , RVs, or construction/farm equipment. In the case of boats, some HCFC - 22 is used in AC systems (UNEP 2003a), but this consumption is accou nted for in this report under stationary AC equipment, such as packaged terminal units or chillers (Cold Ships 2009). HCFC - 22 95.5% HCFC - 123 4.5% HCFC - 124 <1% **2015**

Total: 48,300 MT HCFC - 22 96.6% HCFC 123 3.4% HCFC 124 <1% **2020**

Total: 23,300 MTThe U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 12 **S tationary air** **- conditioning**  includes a wide variety of equipment, further categorized into the following six categories .  Unitary air

- conditioners and heat pumps include both split systems and packaged units and are designed for air circulating, cooling, cleaning, and dehumidify ing and sometimes heating in residential and small and large commercial applications. Wh ile HCFC - 22 systems are still in use, new systems are largely charged with HFC - 134a , R-410A , and R-407C refrigerant blends.  Chillers regulate the temperature and humidity in offices, hotels, shopping centers, and other large buildings. There are two major categories of chillers—centrifugal and positive displacement. Centrifugal c hillers are centralized air conditioning s ys tems ty pically used in larger buildings (e.g., offices, hotels, shopping centers , and other large buildings). Positive displacement chillers are sm a ller and may be water- cooled or air- cooled. There are three principle ty pes of positive displacement chillers— 1) reciprocating , 2) screw, and 3) scroll —each of which is named for the ty pe of compressor employed. HCFC - 22 and HCFC - 123 chillers are still in use, though a portion of the market is transitioning to R-410A, R-407C, and HFC - 134a refrigerants. Historically, these c hillers used CFC - 12, CFC - 11, CFC - 114, and R- 500 refrigerants .  Dehumidifiers are mechanical refrigeration systems designed to remove moi sture from the air by drawing air first over cold evaporator coils and then warm condenser coils, causing the moisture in the air to condense onto the cold coils. Examples include indoor pool dehumidifiers and portable units used to dehumidify basements. E xisting d ehum idifiers still use HCFC - 22 and new systems have transitioned to HFC - 134a and R- 410A.  Water and ground source heat pumps use fluid circulated in a common piping loop as a heat source/sink to cool and heat air. W ater- source heat pumps typically use water pumped from a well, lake, or stream as a heat source/sink. Direct expansion geothermal heat pumps circulate refrigerant through piping in the earth. Wa ter and ground source heat pumps historically used HCFC - 22 ; new s ys tems are charged with HFC - 13 4a, R -410A, and R-407C.  Wi ndow units , also known as room air- conditioners, are small appliances used to condition the air in one room . Wi ndow units historically used HCFC - 22 ; new systems are charged with R-410A.  Packaged terminal units are ACs or heat pumps that are mounted through the wall. They are often used in hotel rooms, dormitories, or classrooms , and historically used HCFC - 22 ; new systems are charged with R-410A.

**Figure 3**  **- 2**  **: Ty**  **pes of A**  **ir -**  **Conditioning Systems a** 

a EPA assumes HCFC refrigerants are not used in MVACs (dashed box) ; shaded end uses are those for which supply and servicing need projections are estimated in this report. 

### Air**- Conditioning (AC)**  **Equipment**

Motor Vehicle AC 

### Stationary Air**- Conditioning** 

Water and Ground Source Heat Pumps Dehumidifiers
Residential Small

Commercial Large

Commercial Other Mobile AC 

### Mobile **Air -**  **Conditioning** Window Units Packaged Terminal AC and Heat Pumps

Centrifugal Chillers

Positive Displacement Reciprocating Screw Scroll Unitary AC and Heat PumpsThe U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 13 

### Refrigeration End

**- Uses**  Refrigeration equipment can be broken down into four categories: domestic refrigeration, refrigerated trans port, industrial process refrigeration, and commercial refrigeration. Figure 3 - 3 below illustrates these categories and identifies those end uses for which supply and servicing need projections are estimated in this report. **Domestic refrigeration** includes household refrigerators, household freezers, combination refrigerator/freezer units, and water coolers. For the majority of these equipment types, the refrigerants used do not typically include HCFCs or blends containing HCFCs. Older household freezers sometimes em ployed HCFC - 22 ; however, because these units are viewed as a minor part of the domestic refrigeration market, this end - use is not further analyzed in this report . **Refrigerated transport** includes refrigeration used in equipment that mov es products from one place to another and includes refrigerated ship holds, truck trailers (i.e., reefer trucks), railway freight cars, and other shipping containers. Refrigerated transport units have historically used R- 502 (an HCFC - 22 blend), but have transitioned to HFC - 134a and R-404A. **Industrial process refrigeration (IPR) systems** are complex, customized systems used to cool process streams in the chemical, food processing, pharmaceutical, petrochemical, and manufacturing industries. This sector also includes industrial ice machines, equipment used directly in the generation of electricity, and ice rinks. IPR systems with HCFC - 22, HCFC - 123, and HCFC - 124 (as R-401A) are still in use though a portion of th is ma rk et has transitioned to HFC - 134a, R-404A, R-410A, and R- 507A. IPR s ys tems historically used CFC - 11 and CFC - 12 . **Commercial refrigeration** can be further broken down into three end - uses:
 Cold storage warehouses are refrigeration systems with varying designs and charge sizes. They are used to store me at, produce, dairy products, and other perishable goods before and after food processing. Cold storage units historically used CFC - 12 , R- 502 , and HCFC - 22 refrigerants ; new systems are charged with R-404A and R- 507A.  Retail food systems are used to refrigerate food in commercial retail establishments, such as grocery stores. These systems can be classified as either centralized systems, condensing units, or self- contained units. Centralized retail food systems, also known as remote systems, consist of a series of compressors located in a remote machinery room, providing a cooling medium to display cabinets and cold storage rooms in other parts of the building. The most common form of centralized s ys tems circulate refrigerant throughout the store. Alte rnatives to these types of systems include secondary loop and distributed systems that largely use HFC refrigerant blends. These large retail food s ys tems historically used CFC - 12 and R- 502 refrigerants ; new systems have transitioned to R-404A, R- 507A, and R-407A. Condensing units are large - or small - size refrigeration equipment with one or two compressors and a condenser installed on the roof or in a sm all m achine room. Examples include walk - in refrigerators, coolers, and freezers. Condensing units histori cally used HCFC - 22 ; new systems are charged with R-404A, HFC - 134a, and R- 507A refrigerants. Self- contained retail food units, also referred to as stand - alone s ys tems, are factory produced with all the components integrated. Examples include roll - in refrige rators/freezers, under- counter refrigerators/freezers, reach - in refrigerators/freezers, wine and beer coolers, ice cream machines, beverage vending machines, and a variety of stand - alone upright or horizontal display cases (e.g., beverage merchandisers, de li cases) . Self- contained refrigeration units historically used CFC - 12 refrigerants and have transitioned to HFC - 134a, R-404A, R- 507A, and CO 2 refrigerants. HCFCs were never used in this application.  Ice makers are factory- ma de units used in commercial establishments to produce ice for consumer use (e.g., in hotels, restaurants, and convenience stores). Ice makers are not further analyzed in this report because they do not typically employ HCFCs or blends containing HCFCs. Ice make rs moved directly from CFC - 12 to HFC - 134a.The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 14 **Figure 3**  **- 3**  **: Ty**  **pes of Refrigeration Systems a** 

a S

a Dashed boxes cover end - uses that are assumed to not use HCFC refrigerants; shaded end - uses are those for which supply and servicing need projections are estimated in this report . Table 3 - 3 presents projected estimates of HCFC refrigerant servicing need for the refrigeration and AC industries. As shown, HCFC - 22 represents the majority of the refrigeration and AC market for 2015 to 2025 . The Vintaging Model also projects continued use through 2020 for HCFC - 124 and through 2025 and beyond of HCFC - 123 as a refrigerant in, or to provide service to, equipment manufactured prior to January 1, 2020 . Although the Vintaging Model does not project servicing need for HCFC - 142b in the 2015 - 2025 timeframe , other information suggests that HCFC - 142b is still in use in niche refrigerant blends. More detail on the projected use of each HCFC in refrigeration and AC applications is provided in the following table .

**Table 3**  **- 3**  **: Projected HCFC**  **- 22,**  **HCFC -**  **123, HCFC**  **- 124**  **, and HCFC**  **- 14** **2b Need**  **for**

**Refrigeration and A ir** **- Conditioning,**  **2015 -**  **202 5**  **(Metric Tons** ) a **HCFC 2015**  **2016 2017**  **2018 2019**  **2020 2025**  HCFC - 22 46,100 41,600 36,700 32,300 27,700 22,500 5,500 HCFC - 123 2,200 2,200 2,200 2,200 2,300 600 500 HCFC - 124 5 5 5 4 4 4 - HCFC - 142b - - - - - - - Source: Based on modeling assumptions from EPA (20 12 ) . a Changes to assumptions in the Vintaging Model since the 2009 Servicing Tail Report have increased projected servicing need. For more detail on the changes , please see Appendix C.
 **HCFC -** **22 —**  Projected HCFC - 22 servicing need from 2015 onward is for AC an d refrigeration applications . AC applications include window units, packaged terminal units, residential and commercial unitary AC, chillers, dehumidifiers, water and ground source heat pumps, and non light duty mobile AC in buses, trains, etc. Refrigeration applications include refrigerated transportation, industrial process refrigeration, and commercial retail food. HCFC - 22 is used as both a stand - alone refrigerant as well as a component in refrigerant blends .  **HCFC -**  **123 —**  HCFC - 123 is used in the refrigeration and AC sector mainly in centrifugal chillers for industrial process refrigeration and commercial comfort AC. The production and import of virgin HCFC - 123 is scheduled for phaseout in 2020 for use in new AC and refrigeration equipment, and in 2030 for use in AC and refrigeration equipment manufactured before January 1, 2020.  **HCFC -**  **124 —**  HCFC - 124 is minimally used as a refrigerant; its primary use as a refrigerant is in blends, mainly R-401A, in industrial process and transport refrigeration equipment , as well as R409A and R-414B in commercial refrigeration a pplications . As a stand - alone refrigerant, it has found some niche applications that reach high condensing temperatures as well as an alternative for CFC - 114 in some naval chillers. Starting in 2020, virgin HCFC - 124 can no longer be use d in new AC and refr igeration equipment . Starting in 2030 , virgin HCFC - 124 can no longer be produced or imported to service existing AC and refrigeration equipment. However, its use in blends R-401A, R-401B, R-409A, R-414A, R-414B and others is constrained because those blend s also contain HCFC - 22 . Starting in 2020, HCFC - 22 will not be produced or imported for use in these blends. HCFC - 124 is also a component of R -416A, which does not contain any other 

### Refrigeration Equipment Domestic Refrigeration **Refrigerated Transport**  **Industrial**

**Process Refrigeration**  **Commercial**

**Refrigeration**
Cold Storage Ice Makers Retail Food Household Refrigerators Household

Freezers Water

CoolersThe U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 15 **Box 3**  **- 2**  **: Summary of**  **Several HCFCs**  **U sed**  **in Refrigerant Blends** Often refrigerants are formulated with several substances, such as hydrofluorocarbons (HFCs) or hydrocarbons (e.g., propane, butane, isobutane ) . Table 3 -4 presents the composition of some of the more common refrigerant blends containing HCFCs . **Table 3**  **- 4**  **: Compositions of Common HCFC Refrigerant Blends (**  **P ercent**  **by W** **eight )**  **Blend HCFC**  **- 22**  **HCFC -**  **124 HCFC**  **- 142b**  **HCFC -**  **123 Other**  R-401A 53% 34% 13% HFC - 152a R-402A 38% 60% HFC - 125, 2 % propane (R- 290) R-409A 60% 25% 15% R- 502 48.8% 51.2% CFC - 115 E nd - uses in which these refrigerant blends containing HCFCs are currently used are presented in the Table 3 - 5 . **Table 3**  **- 5**  **: HCFC**  **- Containing Refrigerant Blends by End**  **- Use**  **Refrigeration Equipment Type**  **Refrigerant Type**

**R -** **401A R** **- 402A**  **R -** **409A R** **- 502**  Retail Food x x x x Cold Storage x x x IPR x Transport Refrigeration x x x ODS. Wh ile feedback from several industry sources indicates there are a min im al number of legacy systems still in use, the number is declining (U.S. HCFC Manufacturer Representatives 2013) .  **HCFC -**  **142b —**  HCFC - 142b is used as a constituent of a few refrigerant blends that have historically served as replacements for CFC - 12 and R - 500 (a blend containing CFC - 12 and HFC 152a) medium - sized refrigeration equipment . Based on refrigerant sales data collected by the California Air Resources Board (see Preliminary 2011 and 2012 Sales and Distribution Data from the California Air Resources Board’ s Refrigerant Management Program in the docket) and information provided by stakeholders , R-409A (composed of HCFC - 22, HCFC - 124, and HCFC 142b) and R- 414B (composed of HCFC - 22, HCFC - 124, HCFC - 142b and R- 600a) are the most common refrigerant blend usi ng HCFC - 142b. Although servicing need for R-409A , R-414B and som e other niche refrigeration needs are not currently modeled in the Vintaging Model , these sources indicate there is continuing, albeit decreasing, servicing need for HCFC - 142b refrigerant blen ds. Box 3 - 2 presents a brief summary of HCFCs use d in refrigerant blends. 16



## 3.3. **HCFC Use in Nonresidential Fire Suppression**  Fire - extinguishing applications can be divided into two categories: portable fire extinguishers ( i . e. , streaming applications) that originally used Halon 1211, and total flooding applications that originally used Halon 1301 or Halon 2402 (EPA 2006) . To replace H alon 1211 in streaming applications, t he Significant New Alternatives Polic y (SNAP) program has listed the use of in - kind substitutes ( e.g. , CO 2 , HCFCs, HFCs , fl uo roketones ) and not- in - kind substitutes ( e.g. , water, dry chem ical, foam) as acceptable . Wh ile
16 HCFC consumption data presented in this analysis include quantities consumed in blends by employing the percent composition of the corresponding HCFC constituent(s) of that blend. In order to accurately portray the number of units containing HCFC blends, however, blends are not disaggregated when presenting the number of units of equipment (i.e., a unit running on an HCFC containing blend counts as one unit).The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 16 the SNAP list includes HCFC - 123, HCFC - 124 , and certain HCFC blends for streaming applications, only HCFC - 123 and HCFC - 124 are used as streaming agents in practice (EPA 2012 ). HCFC - 123 is the primary constituent in Halotron I (also referred to as HCFC Blend B in EPA regulations). Specifically, the blend Halotron I is used in c om me rcial/industrial, maritime, and military applications in the United States (Halotron 2008). HCFC - 124 has some niche fire protection applications for specialty marine systems (pleasure boats) from the 1990s that may still be in use but are not modeled b y the Vintaging Model. HCFC - 124 was primarily used in Europe for fire suppression applications ( Hughes Associates, Inc., 2012 ). This analysis considers fire suppression applications using HCFC - 123 only. In December 2011, House Resolution (HR) 1540 was sig ned into public law. Section 320, Fire Suppression Agents, amends section 605(a) of the Clean Air Act to allow HCFCs to continue to be used after 2015 for nonresid ential fire suppression purposes . Production and import of HCFCs for fire suppression can continue until January 1, 2020, when Article 2F of the Montreal Protocol limits any continued consumption of HCFCs to servicing of refrigeration and AC equipment onl y . Table 3 - 5 presents projected servicing need estimates for HCFC - 123 for fire suppression systems . 17 **Table 3**  **- 5**  **: Projected HCFC**  **- 123**  **Need for Fire Suppression, 2015**  **- 2025 (Metric Tons**  ) **HCFC 2015**  **2016 2017**  **2018 2019**  **2020 2025**  HCFC - 123 190 200 200 210 210 210 * 210 * Source: EPA (2012 ) . * In 2020 through 2025, HCFC - 123 demand is reported for charging portable fire extinguishers with recycled HCFC - 123 based blends. Alternatives to HCFCs in the fire extinguishing industry include the in - kind gaseous agent substitutes listed above for H alon 1211 including CO 2 , HFCs such as HFC - 236fa , and fluoroketones (C6 - perflouroketone also known as Novec TM 1230) (EPA 2012 ).

17 The Vintaging Model does not yet reflect the amendment to section 605(a) of the Clean Air Act; however, a scenario assuming n o phaseout was run to estimate the use of Halotron I, and was compared to industry information for consistency.The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 17 

# 4. **Projected HCFC**  **Scenarios** Section 4 presents projections of the number of HCFC - containing units of equipment and the associated servicing needs for 2015 through 2025 . S cenarios were developed by investigating various trends that are expected to affect future market needs . Such trends include changes in charge sizes, the transition to alternative refrigerants, changes in refrigerant recovery and reuse practices , and HC FC economics .  Section 4.1 summarizes the projected market size of equipment and the servicing need for HCFC - 22 beyond 2015 in the United States .  Section 4.2 summarizes the projected market size of equipment and servicing need for HCFC 123 beyond 2015 in the United States.  Section 4.3 summarizes the projected market size of equipment and servicing need for HCFC 124 beyond 2015 in the United States.  Section 4.4 provides discussion on anticipated HCFC - 142b servicing needs based o n stakeholder feedback.  Section 4.5 discusses the various sources of HCFCs that can be used to meet servicing need , including rec yc led, reclaimed, and imported (used) HCFCs as well as interpollutant transfers of allowances.  Section 4. 6 provides projections of servicing need that can be met by reuse and recovery based on three different recovery scenarios.  Section 4. 7 discusses factors that may affect projections of servicing need and recovery, including: certain equipment specification requirements, the tra nsition to alternative refrigerants, and the stockpiling of refrigerant. Appendix B presents further detail on the estimates provided in Section 4, disaggregating HCFC - 22 , HCFC - 123 , and HCFC - 124 containing equipment and overall servicing need estimates in to end - use specific projections. 

## 4.1. **HCFC -**  **22** The HCFC - 22 equipment and servicing need estimates provided below were developed using EPA’s Vintaging Model (EPA 2012). Appendix A provides more detail on the metho dology used to develop these projections. Appendix B provides projections disaggregated by end - use. 

### 4.1.1. **HCFC -**  **22 Equipment Used Beyond 2015**  The only HCFC - 22 equipment that is projected to be in use (i.e., within the installed base) from 201 5 onward will be used for refrigeration and AC applications , including window units, packaged terminal units, residential and commercial unitary AC, chillers, dehumidifiers, water and ground source heat pum ps, non - light duty mobile AC in buses and trains, retail food, industrial process refrigeration, and transport refrigera tion equipment . As presented in Table 4 - 1 , approximately 95.8 mi llion units of AC equipment will be in use in 201 5 , decreasing from 201 5 levels by about 79 percent by 20 20 , and by over 99 percent by

202 5 . A pproximately 976,600 units of refrigeration equipment will be in use in 2015 . 18 The installed base of refrigeration equipment is projected to decrease from 201 5 levels by about 52 percent by 20 20 and 8 5 percent by 202 5 .

**Table 4**  **- 1**  **: Projected Number of HCFC**  **- 22 Units (201**  **5 -** **202 5**  **) a,b**  **Equipment Type 2015**  **2016 2017**  **2018 2019**  **2020 2025**  Total AC 95,814,200 81,732,700 67,286,500 52,551,500 37,024,700 20,592,800 330,100 Total Refrigeration 976,600 852,700 734,000 639,300 549,900 467,500 145,600 **Total 96,790,800**  **82,585,400 68,020,500**  **53,190,800 37,574,600**  **21,060,300 475,700**  a Including units that use blends containing HCFC - 22. b Because the estimates for cold storage warehouses are expressed in cubic feet, this equipment type is not included in this table. Source: B ased on modeling assumptions using EPA (2012 ) . 18 This estimate is not inclusive of cold storage warehouses.The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 18 **Box 4** **- 1**  **: Sensitivity Analysis on Key Assumptions Affecting** 

**HCFC -**  **22 Servicing Demand System Charge Sizes**  : This sensitivity analysis explores the impacts of a lower 4 kg charge size for 13 SEER HCFC - 22 residential unitary AC equipment rather than the current assumption of approximately 4.8 kg. This change reduces HCFC - 22 servicing need by about 2 - 7 percent pe r year from 2015 to 2023. **Leak Rates:** L eak rate s for residential unitary AC, large and medium retail food refrigeration, and cold storage units may be lower as a result of partnership programs such as GreenChill and more careful servicing. Lower loss rates can reduce HCFC - 22 servicing need by about 10 - 23 percent per year between 2015 and 2025. **Lifetimes:** T he ban on HCFC - 22 in new equipment manufactured after 2010 and price increases for HCFC - 22 are likely to have prompted some end - users to transition away from HCFC - 22 equipment earlier than the end of the equipment’s lifetime. This sensitivity analysis explores the impact on servicing need if 20 percent of residential unitary AC, industrial process refrigeration units, and retail food equipment transitions out of HCFC - 22 five years earlier. These changes can reduce HCFC 22 servicing need by 9 - 14 percent per year between 2015 and 2025. 

### 4.1.2. **Projected HCFC** **- 22 Servicing Needs**  Refrigeration and AC equipment commonly requires servicing, which may include adding refrigerant to account for refrigerant losses that occur over time. 19 Wh ile the production and import of HCFC - 22 was banned for use in new appliances in 2010, it may be permitted for servicing and maintenance purposes until January 1, 2020 . Table 4 - 2 presents projected HCFC - 22 servicing need (including that used in blends) for servicing equipment in 201 5 , 20 20 , and 202 5 . As shown in Table 4 - 2 , approximately 46,100 me tric tons of HCFC - 22 are projected to be required to service AC and refrigeration equipment in 2015 , of which the majority —27,900 me tric tons (6 1 %) —will be used to service AC systems. EPA projects that servicing need for HCFC - 22 in AC and refrigeration equipment will decrease to 22,500 me tric ton s by 20 20 and 5,500 me tric tons by 202 5 . T he 2015 projections of servicing need exceed the U.S. consumption cap for virgin HCFCs; however, a portion of the servicing needs can be met by using recovered refrigerant, thus decreasing the need for virgin HCFC 22. **Table 4**  **- 2**  **: Projected HCFC**  **- 22 Servicing**  **Need (201**  **5 -** **202 5**  **) (Metric Tons) Equipment Type**  **2015 2016**  **2017 2018**  **2019 2020**  **2025** Total AC 27,900 24,900 21,600 18,400 14,900 11,100 360 Total Refrigeration 18,200 16,700 15,100 13,900 12,700 11,400 5,200 **Overall Total 46,100**  **41,600 36,700**  **32,300 27,700**  **22,500 5,500**  Source: B ased on analysis using EPA (2 012 ) . Note: Totals may not sum due to independent rounding. Wh ile assum ptions in EPA’s Vintaging Model are continually updated to refine inputs, the projections of future servicing needs for HCFC 22 can be affected by outside factors that are not fully reflected in the estimates. In addition, as HCFC use decreases and the phaseout approaches, modeling with precision becomes mo re difficult. In recognition of these challenges, sensitivity analyses on the impact of key assumptions on HCFC - 22 servicing need were conducted in response to information from stakeholders . As described in Box 4 - 1 , altering assumptions about system charge sizes, leak rates, and lifetimes can modestly to significantly decrease projected servicing need . For example, more careful servicing practices that result in lower loss rates can reduce servicing need by up to 23 percent per year past 2020. Additional details on these sensitivity analyses are presented in Appendix D. Figure 4 - 1 displays the breakdown of HCFC - 22 servicing need by

AC and refrigeration equipment type for 201 5 and 20 2 0 . As shown, residential AC, retail food refrigeration equipment, and IPR are projected to account for over 90 percent of HCFC - 22 servicing need in 201 5 . By 2020, t hese three end - uses are still projected to account for 90 percent of HCFC - 22 servicing need although IPR’s portion of servicing need is slightly higher than 2015 and residential AC is slightly lower . This trend is partly the result of the modeled lifetimes for these end uses; EPA assumes an average
19 The servicing need estimates projected in this analysis include refrigerant to replace quantities that leak from operating eq uipment as well as de minimis losses that may occur while serv icing operating equipment.The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 19 lifetim e for residential AC of 15 years, while IPR systems are assumed to last 25 years. Differences between modeled average lifetimes and practiced lifetimes can impact actual servicing need for residential and AC equipment , as examined further in Box 4 - 1. **Figure 4**  **- 1**  **: HCFC**  **- 22**  **Need for Servicing**  **Refrigeration and A ir** **- C**  **onditioning Equipment,**  **by End -**  **Use a** 

a Other Equipment” includes window units, packaged terminal units, water and ground source heat pumps, other mobile AC, and refrigerated transport. Source: B ased on data analysis using EPA (2 012 ) . 

## 4.2. **HCFC -**  **123** The HCFC - 123 equipment and servicing need estimates provided below were developed using EPA’s Vintaging Model (EPA 2012). Appendix A provides more detail on the methodology used to develop these projections. Appendix B provides projections di saggregated by end - use. 

### 4.2.1. **HCF C** **- 123 Equipment Used Beyond 2015**  HCFC - 123 is used in the refrigeration and AC sector mainly in centrifugal chillers for industrial process refrigeration and commercial comfort AC. The production and import of virgin HCFC- 123 can be continued for use in refrigeration and AC equipment manufactured prior to 2020; by 2020 its remaining permissible use is for the servicing of this equipment until 2030, when all production and import is b anned. A 2011 am endm ent to s ection 605(a) of the Clean Air Act also allows HCFC - 123, a component of Halotron I, to be used for nonresidential fire sup pression applications . Halotron I is used for commercial/industrial, maritime, and military applications i n the United States (American Pacific 2008). Stakeholders indicate d that they plan to sell extinguishers with virgin material until 2019 and to continue selling extinguishers with recy cled material in 2020 and beyond. 

### 2020 Total Consumption for Servicing: 22,500 MT **2015** Total Consumption for Servicing: 46,100 MTThe U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 20 Alternatives to HCFC - 123 used in fire suppression include the in - kind gaseous agent substitutes listed by SNAP for H alon 1211 including CO 2 , HFCs (e.g., HFC - 236fa ) , and fluoroketones (C6 - perflouroketone , also known as Novec TM 1230) (EPA 2012). A new chemical streaming agent , 2 - b romo - 3,3,3 - trifluoropropene (2 - BTP), has been recently submitted for review to SNAP and EPA’s New Chemicals Program under the Toxic Substances Control Act. According to a recent report of the UNEP Technology and Economic Assessment Panel, “if the developme nt of [2 - BTP] proves commercially successful, owing to its fire extinguishing characteristics being closer to H alon 1211 and it having a low environmental im pact, it would be the natural replacement for [HCFC - 123] and H alon 1211 – particularly in the aviat ion industry” (UNEP 2013). As presented in Table 4 - 3 , approximately 47,6 0 0 units of AC equipment using HCFC - 123 are estimated to be in use in 2015. The number of HCFC - 123 AC units i s projected to de crease from 2015 levels by 16 percent by 2025. A pproximately 12 , 60 0 units of HCFC - 123 refrigeration units are estimated to be in use in 2015, decreasing by approximately 5 percent by 2025. EPA estimates 1,422,100 HCFC - 123 (essentially Halotron I) fire suppression units in use in 2015, which is expected to decrease to 871 , 1 00 by 2025. This estimate for fire suppression is similar to the estimate d of number of units provided by a stakeholder in the industry . **Table 4**  **- 3**  **: Projected Number of HCFC**  **- 123**  **Refrigeration , A**  **ir -**  **C onditioning**  **, and Fire Suppression**  **Units (2015**  **- 2025)**  **Equipment Type 2015**  **2016 2017**  **2018 2019**  **2020 2025**  Total AC 47,600 48,900 50,400 50,900 51,400 49,500 39,800 Total Refrigeration 12,600 13,300 13,900 14,400 14,800 14,300 12,000 Fire Suppression 1,422,100 1,464,800 1,508,700 1,554,000 1,600,600 1,487,800 * 871,100 * **Total 1,482,300**  **1,527,000 1,573,000**  **1,619,300 1,666,800**  **1,551,600 922,900**  Source: B ased on analysis using EPA (2 012 ) . * Estimates of fire suppression units do not include units charged with recycled material. 

### 4.2.2. **Projected HCFC -**  **123 Needs** Table 4 -4 presents projected HCFC - 123 need for charging and servicing equipment before 2020 and for servicing equipment only after 2020 . Table 4 -4 also provides the projected HCFC - 123 servicing need for nonresidential fire suppression s ys tems from 2015 to 2020 . I n 2015, approximately 2,2 00 me tric tons of HCFC - 123 will be required for servic ing and charging refrigeration , AC, and fire suppression units , of which the majority

— 1, 2 00 me tric tons ( 55 %)—will be used to service AC systems. S ervicing need for HC FC - 123 in AC and refrigeration equipment is projected to decrease to 4 70 me tric tons by 2025 . The Montreal Protocol prohibits the production and import of virgin HCFCs for fire suppression beginning January 1, 2020 ; however, stakeholders have indicated that new extinguishers with recycled material will continue to be sold after this date. Servicing needs for HCFC - 123 fire extinguishers sold with rec yc led ma terial is modeled as 210 metric tons from 2019 onwards.The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 21 **Table 4**  **- 4**  **: Projected HCFC**  **- 123**  **Refrigeration ,**  **A ir** **- C**  **onditioning , and Fire Suppression**  **Servicing Need**  **(201 5**  **- 202**  **5 ) (Metric Tons)**  **Equipment Type 2015**  **2016 2017**  **2018 2019**  **2020 2025**  Total AC 1,200 1,200 1,200 1,200 1,200 220 180 Total Refrigeration 770 800 830 850 860 370 290 Total Fire Suppression 190 200 200 210 210 210 * 210 * **Overall Total 2,200**  **2,200 2,200**  **2, 200**  **2,300 800**  **70 0**  Source: B ased on analysis using EPA (2 012 ) . * In 2020 -2025, HCFC - 123 demand is projected for charging portable fire extinguishers with recycled HCFC - 123 based blends. Note: Numbers may not sum due to independent rounding. 

## 4.3. **HCFC -**  **124** HCFC - 124 servicing need is projected by the Vintaging Model through 2020 (EPA 2012). Appendix B provides projections disaggregated by end - use. 

### 4.3.1. **HCFC -**  **124 Equipment Use Beyond 2015** HCFC - 124 is used in the refrigeration sector mainly in industrial process refrigeration and medium retail food refrigeration (small condensing units). The production and import of virgin HCFC - 124 can be continued for use in refrigeration equipment manufactured prior to 2020; by 2020 its remaining permissible use is for the servicing of this equipment until 2030, when all production and import is banned. As presented in Table 4 - 5 , approximately 27,400 units of refrigeration equipment using HCFC - 124 are estimated to be in use in 2015. The number of HCFC - 12 4 refrigeration u nits is projected to de crease to zero by 2025.

**Table 4**  **- 5**  **: Projected Number of HCFC -**  **124 Refrigeration Units (2015 -** **2025) Equipment Type**  **2015 2016**  **2017 2018**  **2019 2020**  **2025** Total Refrigeration 27,400 26,500 25,200 23,500 21,400 18,900 - **Total 27,400**  **26,500 25,200**  **23,500 21,400**  **18,900 -**  Source: B ased on analysis using EPA (2 012). 

### 4.3.2. **Projected HCFC -**  **124 Needs** Table 4 - 6 presents projected mi nim al HCFC - 124 need for charging and servicing equipment before 2020 and for servicing equipment only after 2020. I n 2015, approximately 4 me tric tons of HCFC - 12 4 will be required for servicing and charging refrigeration u nits . S ervicing need for HCFC - 124 in AC and refrigeration equipment is projected to decrease to zero me tric tons by 2025 . **Table 4**  **- 6**  **: Projected HCFC -**  **124 Refrigeration Servicing Need**  **(2015 -** **2025) (Metric Tons) Equipment Type**  **2015 2016**  **2017 2018**  **2019 2020**  **2025** Total Refrigeration 5 5 5 4 4 4 - **Total 5**  **5 5**  **4 4**  **4 -**  Source: B ased on analysis using EPA (2 012). Wh ile the Vintaging Model predicts minimal servicing need for HCFC - 124, feedback from stakeholders and refrigerant sales data collected by the C alifornia A ir R esources B oard indicates the servicing need ma y be higher than projected ( see Preliminary 2011 and 2012 Sales and Distribution Data from the California Air Resources Board’s Refrigerant Management Program in the docket ). This difference is in large part a result of servicing need for R-409A and R- 414B in refrigeration applications, which is not mo deled in the Vintaging Model.The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 22 

## 4.4. **HCFC -**  **142b** HCFC - 142b is predominantly used in refrigerant blends that serve as replacements for CFC - 12 and R500 medium - sized refrigeration equipment. The production and import of virgin HCFC - 142 b is allowed until 2020 for servicing refrigeration equipment manufactured prior to 2010. The Vintaging Model projects that servicing need for HCFC - 142b will be zero after 2015 (EPA 2012); however, the Model does not include servicing need for some niche HCFC - 142b blends such as R-409A. According to refrigerant sales data collected by the California Air Resources Board, R -409A equipment is still in use ( see Preliminary 2011 and 2012 Sales and Distribution Data from the California Air Resources Board’s Refr

igerant Management Program in the docket ). HCFC manufacturers have also indicated that there will be continued, declining need for HCFC - 142b in niche refrigerant blends beyond 2015 . 

## 4.5. **HCFC Sources**  Since January 1, 2010 , only existing sources of HCFC - 22 and a controlled quantity of virgin HCFC - 22 (lim ited through allowance allocations distributed by EPA) are available to the AC and refrigeration industry to meet servicing need . 20 Virgin HCFC - 123 and HCFC - 124 will be permitted for use in appliances ma nu factured prior to January 1, 2020 and virgin HCFC - 142b will be permitted for use in appliances ma nufactured prior to January 1, 2010 . Beyond 2020, only existing sources of HCFC - 123 and HCFC - 124 , and a controlled quantity of virgin HCFC - 123 and HCFC - 124 (li mi ted through allowance allocations distributed by EPA) , will be made available to meet servicing need . Existing sources of HCFCs for servicing equipment include: 1. HCFC refrigerants that are recovered and either recycled or reclaimed before reuse . Under E PA regulations at 40 CFR 82 . 156, refrigerants containing HC FCs must be recovered . After the recovery process, the refrigerant held in the storage container may be: 21 a. Recycled (i.e., cleaned through the use of recycling equipment) and recharged back into the equipment from which it came; b. Recycled and used in other equipment of the same owner; or c. Reclaimed (shipped to an EPA- certified reclaimer) prior to resale to a new owner . 2. Import of used HCFCs that companies can acquire, if the import is preauthor ized by EPA, through a petition process. 3. The conversion of allocations from other chemicals to HCFCs as allowed under the final allocation rule s . Each of these existing sources of HCFCs is described in more detail below. 

### Recycled **HCFC Refrigerants**  Recovered HCFC refrigerants are often recycled prior to being used again in equipment . The recycling process cleans the refrigerant for reuse without meeting all the requirements of reclamation, discussed further below. HCFC refrigerants are commonly recovered from a piece of equipment, adequately cleaned, and then recharged into the same piece of equipment using a recycling device ( EPA 2003b ). EPA regulations allow for the recharge of used refrigerant without subsequent reclamation for refrigerants that a re recovered and charged back into the same appliance or to another appliance if those appliances have the same owner . Several companies, such as supermarket chains, employ recycling plans through which the refrigerant is recovered when dismantling or conv erting one establishment’s equipment and reused to service equipment at another facility with the same ownership. Stakeholder feedback has indicated that recovery and direct reuse is a widespread practice amongst supermarkets in large retail food equipment (ICF 2011 ). Some supermarkets have sufficient recovered HCFC - 22 in - stock for servicing
20 Virgin HCFC - 22 may be stored as inventory; however, the extent to which this activity may occur is unknown. A discussion on inventorying plans is covered in Section 4.5.4. 21 Recovered refrigerants may also be destroyed through the use of environmentally- acceptable technologies that meet the definition of destruction in 40 CFR 82.3 (i.e., liquid injection incineration, reactor cracking, gaseous/fume oxidation, rota ry kiln incineration, cement kilns, and radio frequency plasma) (E PA 2003b).The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 23 such that there is no anticipated need for virgin material before their equipment is retired ( ICF 2011 ). EPA does not collect quantitative data on the amount of HCFC - 22 , HCFC - 123 , HCFC - 124 , or HCFC - 142b that is recycled. 

### Reclaimed **HCFC Refrigerants**  Refrigerants that are resold to be used in other equipment must be reclaimed to a standard level of purity based on the A H RI Standard 700. EPA certified reclaimers are approved to reprocess used refrigerant to at least the purity level based on the A H RI 700 Standard . In 20 1 2 , the amount of HCFC - 22 reclaimed by EPA- certified reclaimers totaled approximately 4,264 me tric tons, or 9.4 mi llion pounds ( EPA 2013 ). Reclamation of HCFC - 22 increased by approximately 13 percent between 2011 and 2012 ; t he higher price of HCFC - 22 is a likely factor in encouraging increased reclamation of the refrigerant. Fewer quantities of the refrigerant blend R - 502, composed of 48.8 percent HCFC - 22 and 51.2 percent CFC - 115, are also being reclaimed , with only 14 me tric tons, or 30,748 pounds reported for 20 12 ( EPA 20 13 ). 22 The amount of HCFC - 123 re claimed in 2012 totaled approximately 143 me tric tons, or 316,340 pounds (EPA 2013). Reclamation data from 200 3 to 20 12 is presented in Table 4 - 7 .

**Table 4**  **- 7**  **: Reclaimed HCFC**  **- 22**  **and HCFC -**  **123 by Year (Metric**  **Tons) 200**  **3 200**  **4 200**  **5 200**  **6 20**  **07 20**  **08 20**  **09 2010**  **2011 201**  **2 HCFC**  **- 22**  1,976 3,280 2,800 3,872 3,716 4,556 3,422 3,622 3,776 4,264 **R -**  **502** 41 48 25 52 34 40 62 1 3 1 9 14 **HCFC -**  **123** 50 114 145 144 103 124 198 165 154 143 Note: HCFC - 124 and HCFC - 142b reclamation data is not available. Source: EPA (20 13 ) . As 201 5 approaches, both the price of HCFC - 22 and reclamation of HCFC - 22 ma y increase. Stakeholders report reclamation capacity of 19,700 MT or m ore that can be mobilized to meet service need , should the price of HCFC - 22 increase or the availability of HCFC - 22 decrease sufficiently to provide increased market incentive for recovery and reclamation ( ICF 2011 ) . A more detailed discussion on HCFC - 22 economics and recovery and reuse practices is provided in Section 4. 5 , “Factors Affecting Projections.” 

### Imports of Used **HCFCs** Unlike virgin HCFCs, used HCFCs are not subject to Montreal Protocol or Clean Air Act restrictions on consumption or use . 23 However, i n creating the allocation syste m for the use of HCFCs, EPA developed a shipment- by- shipment petition process for importing use d HCFCs as described in 40 CFR 82.24 (EPA 2003a).The petition process ensures that HCFCs have been used (and were not newly produced) prior to im port. For each shipment of used HCFC greater than five pounds, the im porter needs to petition EPA at least 40 working days before the shipment is to leave the country of export. EPA reviews and verifies data in the petition and issues either an objection n otice or a non - objection notice to the prospective importer . The projections in this report do not specifically include the po tential future quantities obtained from the im port of used HCFC - 22 , HCFC - 123 , HCFC - 124 , or HCFC - 142b . 

### Interpollutant Transfers of **Allowances** A nother source of H C FCs can result from allowance holders transferring their allowances from one HCFC to HCFC - 22 , HCFC - 123 , HCFC - 124 , or HCFC - 142b which is permitted on an annual and ODP - weighted basis . Section 607 of the Clean Air Act permits year- by- year inter- pollutant transfers of production and consumption allowances . Section 607(b) requires that EPA’s rules are to permit “a production allowance for a substance for any year to be transferred for a production allowance for another substance for the sam e year , ” p lus a 0.1 percent offset to benefit the environment. For example, converting 10 ,00 0 allowance s of HCFC - 12 4 (with an ODP of 0.02 2 ) would result in 3,996 allowances of HCFC - 22 (with an

22 Feedback received from a stakeholder in response to the NODA indicated that because R- 502 is an azeotropic blend, it is difficult and expensive to separate HCFC -22 from the blend, and hence such separation is very limited (National Refrigeran ts 2006). 23 “Used controlled substances” are controlled substances that have been recovered from their intended use systems (which may include controlled substances that have been, or may be subsequently, recycled or reclaimed) (EPA 2003a).The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 24 ODP of 0.05 5) . Allowance holders have converted their allowances to meet market needs historically; this practice is expected to continue, however, the projections in this analysis do not quantitatively assess the potential future quantities that could be obtained from converted allocations. 

## 4.6. **Meeting Refrigeration and AC**  **Service Need**  Although limited production of virgin HCFC s may be allowed to service appliances until 2020 and 2030 through p roduction and consumption allowances , this analysis indicates that, with industry effort, a significant portion of the need for HCFC s for servicing can be met with previously used refrigerant that is recovered and then rec yc led or reclaimed. Increased amounts of recovered HCFCs are a source made available as a result of the venting prohibition EPA has established under Section 608 of the CAA (EPA 2004a). T o determine the potential amounts of used refrigerant available to service equipment, EPA used its Vintaging Model to develop three theoretical scenarios , representing low, baseline and high recovery, to estimate: 1) the amount of recovered HCFCs potentially available to meet servicing need of other equipment still in use; and 2) the subsequent remaining quantity needed to satisfy servicing need . The three scenarios investigated are summarized in Table 4 - 8 . Because no servicing need is projected in the Vintaging Model for HCFC - 142b, no recovery scenarios are modeled for this HCFC. As shown, for HCFC - 22, different recovery rates are modeled fo r the baseline , lower, and higher recovery scenarios. For HCFC - 123 and HCFC - 124 , the recovery rate modeled by the Vintaging Model is used for all three scenarios . The baseline recovery rate s for HCFC - 123 and HCFC - 124 are significantly higher ( 9 0 percent fo r HCFC - 123 and between 80 and 90 percent for HCFC - 124 ) than for HCFC - 22, given HCFC 123 and HCFC - 124 ’s primary use in large r systems, including chillers , IPR , and medium retail food . **Table 4**  **- 8**  **: Summary of Recovery Scenarios**  **Scenario Assumptions**  **for 2015 -**  **20 25**  **HCFC -**  **22 HCFC**  **- 123**  **and HCFC -**  **124 Lower Recovery**  35 percent of refrigerant from retired or retrofitted equipment is

recovered and available for reuse in equipment (i.e., a 35 percent recovery rate). The remaining 65 percent is not available for reuse. The percentage of refrigerant from retired or retrofitted equipment that is available for reuse in equipment is equal to the recovery rate modeled by EPA’s Vintaging Model ( approximately 80 to 90%indust rywide) . **Baseline Recovery**  The percentage of refrigerant from retired or retrofitted equipment

that is available for reuse in equipment is equal to the recovery rate modeled by EPA’s Vintaging Model (approximately 50% industrywide) . **Higher Recovery** 65 percent of refrigerant from retired or retrofitted equipment is

recovered and available for reuse in equipment (i.e., a 65 percent recovery rate). The remaining 35 percent is not available for reuse. Note: HCFC - 123 has a recovery rate of 90% and HCFC - 12 4 has a baseline recovery rate of 80%. In developing the scenarios using the V intaging Model , EPA projected the amount of recovered HCFC based on the quantity available from decom mi ssioned or retrofitted equipment. Wh ile refrigerant recovered from equipm ent during servicing can also be available for reuse in other equipment , this potential source is not included in these scenarios for several reasons. First, it is projected to be minimal in net terms (i.e., refrigerant recovered during service would likely be returned to the same equipment from which it was recovered) . Also, a ccording to industry sources, refrigerant recovered during service events primarily originates from commercial and industrial equipment (i.e., equipment with relatively large ch arges). R efrigerant is rarely recovered during the servicing of small equipment because these units tend not to be overcharged or leaking (Home Energy Center 2006, Airgas 2006). Additionally, only a sm all portion of all servicing events conducted on commercial and industrial equipment involve the refrigerant circuit, and when recovering refrigerant to perform repairs is necessary, often only a section of the refrigerant charge is isolated and recovered, not the entire charge.The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 25 To estimate refrigerant recove ry and reuse, EPA assumed that a certain percentage of refrigerant is recovered from decom mi ssioned or retrofitted e quipment. 24 It is important to note that not all refrigerant is assumed to be recovered. Wh ile EPA has regulations prohibiting intentional ve nting, fo r the purposes of this analysis it is appropriate to create scenarios that assume less than the full charge of refrigerant is recovered at equipment end - of- life. For example, in many instances, equipment is disposed of after a catastrophic failure , which might have resulted in a large or even complete loss of the refrigerant. Also, when equipment is removed from service, there can be losses associated with previous leaks and during attempts to recover the remaining refrigerant. It is also possible that owners or technicians disposing of a piece of equipment might not comply with the regulations and mi ght vent the refrigerant. This analysis then assume s that the entire pool of recovered refrigerant re - enters the market (see Appendix A for more detail s) and can be used to meet a portion of the servicing need for HCFCs . The results of the three recovery scenarios are presented in the sections that follow. 

### 4.6.1. **Servicing Need an**  **d Recovery Projections for HCFC** **- 22**  Ta ble 4 - 9 t o Table 4 - 11 summarize s the projections for HCFC - 22 under each recovery scenario . Ta ble 4 - 9 shows that mo deled HCFC - 22 supplied from recovery or reuse that is available under a Lower R ecovery S cenario would me et 32 percent of servicing need in 201 5 , 72 percent in 20 20 , and 100 percent of servicing need by 2023. Under this scenario , the quantity of recovered HCFC - 22 projected to be available before 2023 is inadequate to meet all of the projected servicing need . Given the ban on remaining production and import of virgin HCFC - 22 in 2020, these modeling results suggest that industry ma y face a shortfall for 2020, 2021, and 2022. Shortfalls in 2015 and 2016 also exist based on limits set under the Montreal Protocol ( see Section 4.6.4 ). For the Baseline Recovery Scenario ( Table 4 - 10 ) and Higher Recovery Scenario ( Table 4 - 11 ), the mo deled am ount of recovered material is sufficient to meet total servicing need for HCFC - 22 equipment starting in 2020 and 2019, respectively . In the Baseline Recovery and Higher R ecovery S cenarios, the am ount of recovered material is more than double the servicing need starting in 2024 and 2023, respectively . As noted in Section 4.1.2 , the sensitiv ity analys e s conducted on key modeling assumptions suggests that HCFC - 22 servicing need could be marginally to significantly less than what is presented in the following tables, depending on the extent to which leak rates, charge sizes, and equipment lifet im es are lower than what the Vintaging Model currently assumes. Information provided by stakeholders indicates that increasing prices for HCFC - 22 may have motivated servicing technicians to be more careful with refrigerant and equipment owners to move more rapidly to alternatives. Wh ile the impact of these sensitivity analyses on HCFC - 22 recovery or reuse has not been explicitly modeled, the results suggest that the need for virgin HCFC - 22 may also be less than what is presented in the following tables.

24 To calculate the amount recovered, the Vintaging Model assumes equipment contains a full charge at disposal and assumes a certain percent of that is recovered. It does not take into account a) refrigerant destroyed after equipment is decommissioned or b) any inventory of recovered refrigerant banked beyond a one -year timeframe. See Appendix A for further details.The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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**Ta ble**  **4 -** **9 :**  **Lower Recovery Scenario: 35% Recovery Rate Summary of Projected**  **HCFC -** **22 Supply**  **and Servicing Need**  **(Metric Tons) a**  **2015 2016**  **2017 2018**  **2019 2020**  **2021 2022**  **2023 2024**  **2025 b**  Total HCFC - 22 Servicing Need 46,100 41,600 36,700 32,300 27,700 22,500 17,900 13,700 10,100 6,900 5,500 Modeled HCFC 22 Supplied from Recovery or Reuse 14,600 14,000 14,700 14,400 15,000 16,200 14,300 12,100 10,900 9,500 4,800 Estimated Supply Needed to Satisfy Remaining Servicing Need 31,500 27,500 22,000 18,000 12,700 6,300 3,600 1,700 0 0 800 % of Total Servicing Need Supplied by Modeled Recovery/Reuse 32% 34% 40% 44% 54% 72% 80% 88% >100% >100% 86%

a B ased on analysis using EPA (20 12 ) . b The values presented for 2025 do not take into account the possibility of carry ing over surplus HCFC -22 from 2023 and 2024. The carryover of surplus HCFC s could help meet the total servicing need for HCFC -22 in 2025. **Table 4**  **- 10**  **: Baseline**  **Recovery Rate Scenario**  **Summary of Projected HCFC**  **- 22**  **Supply and**  **Servicing Need (Metric Tons)**  **a 2015**  **2016 2017**  **2018 2019**  **2020 2021**  **2022 2023**  **2024 2025**  Total HCFC - 22 Servicing Need 46,100 41,600 36,700 32,300 27,700 22,500 17,900 13,700 10,100 6,900 5,500 Modeled HCFC - 22 Supplied from Recovery or Reuse 21,300 20,800 21,800 21,100 21,800 23,100 20,700 18,100 17,000 15,600 10,800 Estimated Supply Needed to Satisfy Remaining Servicing Need 24,800 20,700 14,900 11,300 5,900 0 0 0 0 0 0 % of Total Servicing Need Supplied by Modeled Recovery/Reuse 46% 50% 59% 65% 79% >100% >100% >100% >100% >100% >100%

a B ased on analysis using EPA (20 12) . Note: Totals may not sum due to independent rounding.The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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**Table 4**  **- 11**  **: Higher Recovery Scenario**  **: 65**  **% Recovery Rate Summary of Projected**  **HCFC -** **22 Supply**  **and Servicing Need**  **(Metric Tons) a**  **2015 2016**  **2017 2018**  **2019 2020**  **2021 2022**  **2023 2024**  **2025** Total HCFC - 22 Servicing Need 46,100 41,600 36,700 32,300 27,700 22,500 17,900 13,700 10,100 6,900 5,500 Modeled HCFC - 22 Supplied from Recovery or Reuse 27,200 26,100 27,300 26,700 27,800 30,100 26,500 22,400 20,200 17,700 8,900 Estimated Supply N eeded to Satisfy Remaining Servicing Need 18,900 15,500 9,400 5,700 0 0 0 0 0 0 0 % of Total Servicing Need Supplied by Modeled Recovery/Reuse 59% 63% 74% 83% >100% >100% >100% >100% >100% >100% >100%

a B ased on analysis using EPA (20 12) . Note: Totals may not sum due to independent rounding. 

### 4.6.2. **Need and Recovery Projections for**  **HCFC -**  **123** Table 4 - 12 summarize s the projections for HCFC - 123 under the Baseline R ecovery rate scenario . HCFC 123 need is mo deled for both servicing and initial charging of new AC equipment and fire suppression systems; however, only servicing need is assumed to be able to be met by recovered material. The table provides the mo deled servicing need for HCFC - 123, the amount of HCFC - 123 servicing need that can be me t by recovery/reuse, as well as additional need for new equipment. As shown in Table 4 - 12 , the projected amount of recovered and reused HCFC - 123 will meet total servicing need needs starting in 20 20 . Chillers and IPR equipment have high baseline recovery rates (90%), thus larger v olum es of refrigerant can be reused for servicing. Unlike HCFC - 22, HCFC - 123 servicing need is not expected to decrease significantly over the 2015 to 2025 timeframe. **Table 4**  **- 12**  **: Baseline**  **Recovery Rate Scenario Summary of Projected**  **HCFC -**  **123 Supply**  **and Servicing Need**  **(Metric Tons) a** 

**2015 2016**  **2017 2018**  **2019 2020**  **2021 2022**  **2023 2024**  **2025** Total Servicing Need (MT) 610 600 590 600 610 580 560 540 520 490 470 Additional Servicing Need for Charging New Equipment (MT) b 1,600 1,600 1,600 1,600 1,700 210 210 210 210 210 210 Anticipated HCFC - 123 Supplied from Recovery or Reuse (MT) 330 330 330 820 920 9 70 1,02 0 1,03 0 1,04 0 1,05 0 1,06 0 Estimated Supply Needed to Satisfy Remaining Servicing and New Equipment Need 1,900 1,900 1,900 1,400 1,400 0 0 0 0 0 0 % of Total Servicing Need Supplied by Anticipated Recovery/Reuse 15% 15% 15% 36% 40% >100% >100% >100% >100% >100% >100%

a B ased on analysis using EPA (20 12) . b Servicing Need for Charging New Equipment” refers to need associated with new refrigeration and AC units (before 2020) and charging fire suppression systems . Starting on January 1, 2020, the HCFC - 123 need is reported for charging portable fire extinguishers with recycled HCFC - 123 based blends. Note: Totals may not sum due to independent rounding.The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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### 4.6.3. **Servicing Need and Recovery Projections for HCFC** **- 124**  Table 4 - 13 summarizes the projections for HCFC - 124 under the Baseline Recovery rate scenario . HCFC 124 need is modeled for servicing of new refrigeration equipment. The table provides the mo deled servic ing need for HCFC - 12 4 and the amount of HCFC - 12 4 servicing need that can be met by recovery/reuse . As shown , the projected amount of recovered and reused HCFC - 12 4 will meet total servicing needs starting in 20 20 . Medium Retail Food and IPR equipment have high baseline recovery rates ( 80% ), thus larger volumes of refrigerant can be reused for servicing. **Table 4**  **- 13**  **: Baseline**  **Recovery Rate Scenario Summary of Projected**  **HCFC -**  **124 Supply**  **and Servicing Need**  **(Metric Tons) a**  **2015 2016**  **2017 2018**  **2019 2020**  **2021 2022**  **2023 2024**  **2025** Total HCFC - 124 Servicing Need 5 5 5 4 4 4 3 2 1 <1 - Modeled HCFC 124 Supplied from Recovery or Reuse <1 1 1 1 2 9 17 14 11 7 4 Estimated Supply Needed to Satisfy Remaining Servicing Need 4 4 4 3 2 0 0 0 0 0 0 % of Total Servicing Need Supplied by Modeled Recovery/Reuse 8% 16% 24% 31% 41% >100% >100% >100% >100% >100% -

a B ased on analysis using EPA (20 12) . As mentioned previously, feedback from stakeholders and CARB data indicate this number is low. Note: Totals may not sum due to independent rounding. 

### 4.6.4. **Summary of HCFC -**  **22 ,**  **HCFC -**  **123 , and HCFC** **- 124**  **Servicing Need and**  **Recovery Projections** Figure 4 - 2 , Figure 4 - 3 , and Figure 4 -4 illustrate the projected supply of recovered refrigerant available to me et servicing need under the Lower Recovery Scenario , the Baseline Recovery Scenario , and Higher Recovery Scenario , as well as its subsequent importance in meeting future servicing need . T hese figures display servicing need and supply projections of HCFC - 22 , HCFC - 123 , and HCFC - 124 summed together and expressed in ODP - weighted quantities to compare to the ODP - weighted HCFC consumption cap for the United States. The solid line indicates the total HCFC projected servicing need between 2015 and 2025 while the dotted line indicates the U.S. HCFC consumption cap ( the value of the HCFC consumption cap does not change between the three scenarios) . Shading in the figures represents supply. The dark grey shading indicates the portion of projected supply that is available through recovered and reusable HCFCs under the scenario in question. The remaining portion o f servicing need t hat cannot be met is shad ed a lighter grey to represent virgin supply that would be required to meet mo deled servicing need . Figure 4 - 2 illustrates that a virgin sup ply that exceeds the U.S. HCFC consumption cap would be necessary to meet modeled servicing need during some years between 2015 and 2025 , given the amount of material recovered under this scenario . Virgin HCFCs are needed to me et mo deled servicing need under the Lower Recovery Scenario through 2022 and in 2025 . Figure 4 - 3 and Figure 4 -4 illustrate that , between 2015 and 2020, the projected supply from recovered HCFC s combined with a smaller supply from virgin material that is below the U.S. cap is sufficient to meet mo deled HCFC servicing need under the Baseline Recovery and Higher Recovery Scenarios . In addition, beyond 2019, the projected supply from recovered HCFC s exceeds the HCFC servicing need projections .The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 29 Note: In 2025, HCFC -22 recovery is not projected to fully meet service need under this scenario.

**Figure 4**  **- 2**  **: Total Projected HCFC Demand,**  **Lower Re covery Scenario** 

**Figure 4**  **- 3**  **: Total Projected HCFC Demand,**  **Baseline Recovery Scenario**The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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## 4.7. **Factors Affecting Projections** Several market dynamics a ffect the projections of future servicing needs for HCFCs . Certain equipment specification requirements , the transition to alternative refrigerants, surplus inventory of refrigerant , as well as equipment manufactured with HCFCs for sale after the phaseout can all potentially alter the projected servicing scenarios . Each of these issues is discussed further below . 

### 4.7.1. **Transitioning to Alternative Refrigerants** A wide range of alternative refrigerants found acceptable under EPA’s SNAP pro gram are available in the AC and refrigeration sector . Hydrofluorocarbon (HFC) alternatives, including HFC - 134a , R-410A (composed of HFC - 32/HFC - 125), R-407C (composed of HFC - 32/HFC - 125/HFC - 134a), R-404A (composed of HFC - 125/HFC - 143a/HFC - 134a), and R- 507A ( composed of HFC - 125/HFC - 143a), are most widely used in refrigeration and AC equipment. Other alternatives —found acceptable under EPA’s SNAP program for specific end - uses, and sometimes with use condition s—are not only ozone -friendly but also climate -friendly, includ ing hydrocarbons, carbon dioxide, ammonia, and lower- GW P fluorinated refrigerants, such as HFO - 1234ze(E) . The pace of transition to equipment using these alternatives has varied by industry and type of equipment. P roduction and im port of new refrigeration/AC equipment using HCFC - 22 has been prohibited in the United States as of January 1, 2010. Several AC and refrigeration equipment manufacturers had discontinued production of new equipment using HCFC - 22 well before this phaseout d ate (Hill Phoenix 2009; Hussmann 2009; Kysor/ Wa rren 2009; Johnson Controls 2009). Such actions were consistent with those taken in the mid - 1990s, when the refrigeration and AC industries phased out CFC refrigerants from new production chillers, refrigerato rs, motor vehicle air conditioners, and other products two or more ye ars before the 1996 CFC consumption phaseout. Feedback from numerous points in the supply chain has indicated that sales of alternative refrigerants have increased dramatically since 201 1. As the phaseout progresses, the percentage of HCFC - 22 servicing need me t by retrofit refrigerants is expected to rise, thereby further reducing the need for HCFC 22 and adding to the potential inventory of re covered refrigerant.

**Figure 4**  **- 4**  **: Total Projected HCFC Demand,**  **Higher Recovery Scenario**The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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### A **ir -**  **Conditioning Industr y**  HFC - 134a , R-410A, and R- 407C are replacing HCFC - 22 in new stationary and mobile AC equipment . Som e m obile AC equipment has been using alternatives since the early 1990s, with some buses and trains using HFC - 134a , and some heavy rail cars using R -407C (W M ATA 2005; Amtrak 2005; Motorcoach Training 2005; Greyhound 2005; Carrier Corporation 2005b) . Stationary AC equipment using R-410A has been commercially available since 1996 (HARDI 2004), and is the standard refrigerant in all systems installed after 2009 i n the U.S. residential market ( J.P. Morgan 2011 ) . Manufacturers of R-410A saw significant growth in 2010 driven by the conversion to R -410A from HCFC - 22 in the U.S. Between 2009 and 2010, R- 410A residential AC units as a percentage of all condensing unit shipments rose from 55% to 90% due to the phaseout of HCFC - 22 (J.P. Morgan 2011). Since January 1, 2010, new appliances charged with HCFC - 22 could no longer be sold on the market; however, dry- shipped replacement p arts ( e . g ., condensing units , compressors ) are still allowed. Consumers have the option of selecting to repair existing HCFC - 22 units rather than switching to alternatives. A replacement compressor would cost $1,800 to $2,000 , approximately 40 percent of t he cost of a n R-410A s ys tem replacement (J.P. Morgan 2011). This analysis does not take into account the possibility that repairs may extend the lifetime of existing HCFC - 22 appliances but the impact of extended equipment lifetime due to dry- shipped replac em ent parts is considered in Appendix D . EPA’s assumption that residential AC typically lasts for 15 years is consistent with the U.S. Department of Energy (DOE)’s estimates for the average life of a system, which is estimated at 1 5 - 2 0 ye ars ( DOE 2012 ). 

### Refrigeration Industry Advanced refrigeration technologies (e.g., distributed systems and secondary loop systems) represent an estimated 40% of new equipment sales and are generally charged with HFC refrigerants (Hill Phoenix 2009; Hussmann 2009) . The current trend in the supermarket industry is to use HFC refrigerant blends, particularly R-407A . There has been a shift from R-404A towards blends with lower GW Ps, such as R407A and R-407C (Verisae 2009) . Carbon dioxide has been used as a secondary fluid in s upermarkets since 2006 and more recently as a primary refrigerant. It is anticipated that the use of carbon dioxide as a primary refrigerant will become increasingly common in commercial and industrial applications (Shecco 2 012). Based on an industry survey , HCFC - 22 accounts for approximately 40% of the refrigerants (by weight) still used by supermarkets ( Garry 2012). Of the 2,445 retailers surveyed, most did not plan to fully replace HCFC - 22 until 2015 or 2020 ( Garry 2012 ). 

### 4.7.2. **Recovery and Reuse Practices** As indicated in the total projected servicing need scenarios presented in Section 4. 4 , recovered HCFC - 22 and HCFC - 123 that is rec ycled, inventoried , or reclaimed will likely need to increase to satisfy future servicing needs that cannot be met through virgin supplies . Ke y findings from this analysis include: 

### HCFC**- 22**   In 201 5 , the amount of recovered HCFC - 22 refrigerant is projected to range from 21, 300 to 2 7, 200 me tric tons, depending on the percentage of total available refrigerant from retired or converted equip me nt that is recovered and reused .  Since virgin production of HCFC - 22 for domestic use stops in 2020, recovery would have to be at approximately the baseline recovery scenario rate ( 5 1 percent) or higher to meet estimated servicing need (assuming no existing inventory , and not considering the assumptions in the sensitivity analyses ).  In 2025, the availability of recovered HCFC - 22 refrigerant under the baseline and higher recovery scenarios would provide adequate supplies to meet estimate d servicing need . In the lower recovery scenario, servicing need could potentially be met if surplus HCFC - 22 from previous years is carried over.The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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### HCFC**- 123**   In 2015, the amount of recovered HCFC - 123 refrigerant is projected to be 33 0 me tric tons, based on a baseline refrigerant recovery rate of 90 percent .  Starting in 2020, recovered HCFC - 123 refrigerant is expected to me et estimated servicing need . 

### HCFC**- 124**   In 2015, the amount of recovered HCFC - 124 refrigerant is projected to be less than 1 me tric ton . By 2020, the availability of recovered HCFC - 124 refrigerant would provide adequate supplies to meet estimated servicing need . Although there is the potential for supply tightness the closer it gets to 2020 , proper ma intenance practices during the lifetime of equipment, recovery practices at the time of equipment disposal or decommissioning, and the full penetration of reclaim and reuse practices can greatly reduce the likelihood of future shortfalls . The use of recovery procedures during the lifetime of equipment and at the time of decommissioning reduces potential em issions of refrigerant and increases the available supply of refrigerant. End - users of AC and refrigeration equipment must have equipment installed by trained technicians. They must also have their equipment properly maintained to reduce incidences of major leaks. Service technicians must take efforts to isolate components or recover refrigerants prior to service as venting (releasing) HCFC (and CFC and HFC) refrigerant when making repairs is illegal. Service practices that involve locating and repairing leaks in lieu of “topping off” leaking systems further ensure future supplies of HCFC refrigerant. As with servicing procedures, the venting of refrigerant during decommissioning is illega l. Th e AC and refrigera tion community, including end - users, service technicians, and all affected stakeholders, must position itself for approaching phaseouts of HCFCs by using proper recovery techniques and complying with regulations that are in place to promo te the growth of HCFC recovery and reuse . 

### 4.7.3. **Recycling**

**, Reuse, and**  **Managing Inventory** Wi th proper storage tanks, a reserve of recovered HCFC - 22 can be collected, stored, and accessed to service equipment owned by the same company years later, when HCFC - 22 is expected to be less affordable and less available . A report released in 1995 by the Food Marketing Institute (FMI) included a survey issued to supermarket operators on the use of refrigerant management plans (RMP s ) as a strategy to ensure an adequate suppl y of CFC refrigerants for use after the December 31, 1995 , CFC production phaseout . Of those surveyed, 52 percent were banking recovered CFC refrigerant, an activity adopted primarily by store operators with 11 or more stores (FMI 1995) . Industry sources suggest that recovery and direct reuse is a widespread practice amongst supermarkets in large retail food equipment; however, the extent can vary significantly between chains, depending largely on the extent to which supermarkets are converting their HCFC - 22 equipment to alternatives (ICF 2011 ) . Some supermarkets who have converted a substantial proportion of their HCFC - 22 equipment indicated that they have sufficient recovered HCFC - 22 in - stock for servicing such that they do no t anticipate a need to purch ase any more virgin material in the future ( ICF 2011 ) . Feedback from industry sources indicates there was a significant amount of HCFC - 22 in the supply chain leading into 2012 (ICF 2011 ) . Additionally, EPA collected data on HCFC - 22 inventory from nine co mp anies in early fall, 2013 using Clean Air Act section 114 authority. Additional discussion of HCFC - 22 inventory levels is included in Appendix E . Some of th e pre - 2012 inventory was consumed in 2012 to me et servicing needs but both anecdotal feedback and inventory data continue to indicate that there is a significant amount of inventory that can help meet servicing need in 2015 and beyond. 

### 4.7.4. **HCFC -**  **22 Economics** Another factor that affects the projections of HCFC - 22 servicing supply and need is the cost of virgin and reclaimed HCFC - 22 . Prior to 201 2 , the price of HCFC - 22 remained low . The relatively low cost of virginThe U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 33 HCFC - 22 in the market , and the costs associated with sending recovered HCFC - 22 to reclaimers, decreased the incentives to prop erly manage HCFC - 22 in existing s ys tems ( e.g., fixing leaks, recovering and rec yc ling refrigerant, etc.). As the allowed production and import of virgin HCFC - 22 decreased in 2012 and 2013, HCFC - 22 price increased. As a result, interest in and demand for recovery and reuse, reclamation , and retrofit options increased significantly. As the supply of virgin HCFC - 22 continues to decrease, demand for recovered and reclaimed refrigerant and demand for HCFC - 22 alternatives is expected to increase. All of these factors could affect realized lifetimes for equipment, which could decrease future servicing need. A sensitivity analysis shows that shortening realiz ed lifetimes by five years in 20 percent of equipment could result in a 9 to 14 percent decrease in HCFC - 22 service need between 2015 and 2025. Additional details can be found in Appendix D. 

### 4.7.5. **Increasing Seasonal Energy Efficiency Ratio (SEER)** In 2001, the DOE set a stricter seasonal energy efficiency ratio (SEER) standard for resident ial unitary ACs and heat pumps. The minimum efficiency standard of residential unitary ACs and heat pumps was raised by 30 percent to a 13 SEER for all such units manufactured for sale on or after January 23, 2006 (DOE 2001; DOE 2004). The se increased SEER requirements are reflected in the Vintaging Model . T he projections provided in this analysis do not consider the need for HCFC - 22 to service higher efficiency residential AC equipment installed after 2015 because all new HCFC - 22 systems were banned starti ng in 2010 (see Appendix A for more details). The Vintaging Model currently assumes that the 13 SEER vintage of HCFC - 22 residential unitary AC equipment uses a charge size of approximately 4.76 kg. Appendix D presents an analysis that examines the potent ial effects on service need of a lower charge size of 4 kg for HCFC - 22 13 SEER residential unitary AC equipment. This change results in a 2 to 7 percent decrease in total HCFC - 22 service need across all refrigeration and AC end - uses between 2015 and 2023. As modeled , all HCFC - 22 residential unitary AC equipment has reached end - of- life by 2023 , so there is no longer servicing need for that end use after 2023 . 

### 4.7.6. **Lower Loss Rates** EPA’s GreenChill program is committed to reducing refrigerant emissions by lowerin g equipment leak rates or eliminating leaks entirely within the commercial refrigeration industry. Approximately 20 percent of U.S. supermarkets participate in GreenChill. Increased participation in this program can lower the industry- wide leak rate for HC FC - 22 equipment and therefore further decrease HCFC - 22 servicing need . Since 2008, the average commercial refrigeration emissions rate across GreenChill partners has been 13 percent, which is nearly half the national average of 25 percent. 25 In addition, the ban on HCFC - 22 in new equipment manufactured after 2010 (and the resultant increase in price for virgin and reclaimed HCFC 22) may also prompt service technicians to be more careful during servicing and encourage end - users to have leaks fi xed m ore frequently, particularly for larger equipment, where the financial benefits of leak tightness are more apparent. Both of these factors can affect projections of future servicing needs for HCFC - 22, particularly in residential unitary AC, large re tail food, medium retail food, and cold storage. Reducing HCFC - 22 loss rates was found to result in a 10 to 23 percent reduction in HCFC - 22 servicing need s. Details on this sensitivity analysis are presented in Appendix D.

25 The Vintaging Model assumes an annual leak rate of 25 percent for HCFC - 22 large retail food units, plus an annual 5 percent loss during servicing.The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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# 5. **Conclusion** On January 1, 2015, production, import, introduction into interstate commerce and use of HCFCs are banned except for on - going refrigeration and AC service needs for equipment manufactured on or before December 31, 2019 and for nonresidential fire suppression. To sup port development of the allocation levels that will allow the U.S. to comply with the Montreal Protocol’s 2015 and 2020 reduction steps, this report provides projections on the quantity of HCFC - 22 , HCFC - 123 , and HCFC - 124 needed for (a) servicing AC and refrigeration equipment manufactured before January 1, 2020 26 ; (b) charging new AC and refrigeration equipment between 2015 and 2020 (HCFC - 123 only); and (c) nonresidential fire suppression applications before January 1, 2020. Under the B aseline and H igher R ecovery scenarios developed in this analysis, future H C FC servicing needs can be met by using recovered refrigerant and a n am ount of virgin refrigerant allowable under the United States’ Montreal Protocol cap . If recovery and reuse is lower than expected ( i.e., the lower recovery rate scenario), the refrigeration and AC industry could face the potential risk of a shortage of HCFC - 22 starting in 2015 , however, this is unlikely. Alternatively, if leak rates, practiced equipment lifetimes, and charge sizes are lower than what the Vintaging Model currently assumes —as considered in the sensitivity analysis in Appendix D —servicing need , as well as the need for virgin supply, could be significantly lower than what is presented below. The tables below summarize to tal projected HCFC - 22, HCFC - 123 , and HCFC - 124 servicing need in 2015, 2020, and 2025 compared to the ODP - weighted HCFC consumption cap. The percentage shown in parentheses is the percent of servicing need me t by either recovered or virgin HCFCs. Concluding points are also provided on the implications of the three recovery and reuse scenarios.
 In 2015, the projected servicing need for HCFC - 22 , HCFC - 123 , and HCFC - 124 is equal to 2,580 ODP - weighted MT. As shown in Table 5 - 1 , under a higher recovery scenario, 58 percent of this need could be met with recovered refrigerant; and 45 percent of servicing need can be met at the baseline recovery rate. Only 31 percent of the total servicing need can be met under the lower recovery rate scenario, leading to a potential shortage of about 2 44 ODP - weighted metric tons in 2015. **Table 5**  **- 1**  **: Comparison of HCFC Servicing and New Equipment Servicing Need**  **Projections and Necessary Supply Projections by Source**  **(ODP -** **Weighted Metric Tons and Percent) ,**  **2015 2015**  **Lower Recovery Rate**  **Baseline**

**Recovery Rate Higher Recovery**  **Rate** Cap a 1,524 Servicing Need 2,580 Necessary Supply Recovered 812 (31% ) 1, 177 (46 %) 1, 502 (58% ) Virgin 1,524 (59% ) 1, 402 ( 54 %) 1, 078 (42% ) Shortfall 2 44 (10% ) 0 (0% ) 0 (0% ) a HCFC consumption cap expressed in ODP -weighted metric tons. Source: Based on modeling assumptions using EPA (2012).
 In 2020, the HCFC consumption cap is reduced to 0.5 percent of the baseline, or 76.2 ODP - weighted me tric tons. P rojected servicing need for 2020 is 1, 25 5 ODP - weighted MT. As shown in Table 5 - 2 under the baseline and higher recovery scenarios, sufficient supplies of recovered material will be available to meet servicing need s , and no shortage is expected. For the lower recovery scenario, 73 perc ent of t h e total servicing need can be met by recovered and reused material, resulting in a shortage of at least 2 69 ODP - weighted metric tons. EPA regulations prohibit consumption of HCFC 22 and HCFC - 142b in 2020, but allow consumption of HCFC - 123 and HCFC - 124 . Wh ile this analysis projects that all servicing need for HCFC - 123 can be met from recovered supplies, it is worthwhile to

26 New appl iances charged with HCFC - 22 and HCFC - 142b cannot be manufactured as of January 1, 2010.The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 35 note that the total projected HCFC - 123 servicing need of 580 metric tons (11.6 ODP - Tons) is 15% of the total HCFC cap. **Table 5**  **- 2**  **: Comparison of HCFC Servicing Need**  **Projections and Necessary Supply Projections**

**by Source (ODP -** **Weighted Metric Tons and Percent), 20 20**  **2020 Lower Recovery**  **Rate Baseline** 

**Recovery Rate Higher Recovery**  **Rate** Cap a 76.2 Servicing Need 1,25 5 Necessary Supply Recovered 9 10 ( 7 3 %) 1, 2 89 (100% ) 1, 6 73 (100% ) Virgin 76 .2 (6 % ) 0 (0% ) 0 (0% ) Shortfall 26 9 ( 21 %) 0 (0% ) 0 (0% ) a HCFC consumption cap expressed in ODP -weighted metric tons. Source: Based on modeling assumptions using EPA, 2012.
 In 2025, HCFC servicing need is projected at 31 8 ODP - weighted MT ( Table 5 - 3 ). There is no projected shortfall in any of the scenarios considered. For the lower recovery scenario, recovered and reused supplies can meet 89 % of the total servicing need . The remaining ne ed can be met with virgin ma terials without exceeding the consumption cap. No virgin material is expected to be needed for the baseline and higher recovery scenarios. Wh ile t he Clean Air Act allows consumption of HCFC - 123 and HCFC - 124 until 2030 , EPA has not ye t proposed allowances for the 2020 - 2029 timeframe . W hile this analysis projects that all servicing need for HCFC - 123 can be met from recovered supplies, it is worthwhile to note that the total projected HCFC - 123 servicing need of 680 me tric tons ( 13. 7 ODP Tons) is 1 8 % of the total HCFC cap. **Table 5**  **- 3**  **: Comparison of HCFC Servicing Need**  **Projections and Necessary Supply Projections by Source (ODP**  **- Weighted Metric Tons and Percent), 2025**  **2025 Lower Recovery**  **Rate Baseline** 

**Recovery Rate Higher Recovery**  **Rate** Cap a 76 .2 Servicing Need 31 8 Necessary Supply Recovered 284 ( 89 %) 616 (100% ) 509 (100% ) Virgin 34 ( 1 1 %) 0 (0% ) 0 (0% ) Shortfall 0 (0% ) 0 (0% ) 0 (0% ) a HCFC consumption cap expressed in ODP -weighted metric tons to represent allocations of HCFC -22 and HCFC - 123. Source: Based on modeling assumptions using EPA, 2012. 

###  Although no servicing need for HCFC - 142b is projected from 2015 to 2020, stakeholder feedback and industry data from California indicate t hat there is still equipment using HCFC - 142b and that there will be continued , but limited, refrigerant servicing need beyond 2015. Projections of future HCFC supply and servicing need vary depending on various market trends as addressed in this report. More rapid equipment transition s, reduction s in loss rates through careful servicing and programs such as GreenChill , and lower charge sizes in more efficient equipment may result in lower service need , and consequently lower need for virgin supply . Th e projections in this report provide only some of the information necessary for taking initial steps in determining post- 2015 servicing needs for HCFC - 22, HCFC - 123 , HCFC - 124 , and HCFC - 142b equipment.The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 36 **Box A -**  **1: Developing and Maintaining EPA’s Vintaging Model**  The Vintaging Model synthesizes data from a variety of sources, including:  EPA’s ODS Tracking System and submissions to the SNAP program, both maintained by th e U.S. EPA Stratospheric Protection Division;  Published literature from the United Nations Environment Programme (UNEP) Technical Op tions Committees, the Alternative Fluorocarbons Environmental Acceptability Study (AFEAS), and those provided in industry- related and EPA conference proceedings; and  Nume rous representatives at companies and trade associations , such as the Alliance for Responsible Atmospheric Policy, the Air- Conditioning Heating and Refrigeration Institute (AHRI), the Association of Home Appliance Manufacturers (AHAM), and th e Alliance of Automobile Manufacturers . In some instances the unpublished information that EPA uses in the model is classified as Confidential Business Information (CBI). The annual emissions inventories of chemicals are aggregated in such a way that CBI cannot be inf

erred. The Vintaging Model is continually updated to improve assumptions and modeling techniques and refine inputs based on information received from these sources. EPA shares the revised assumptions and results of model improvements with industry throug h publications such as this one as well as through presentations, such as those given at the April 2007 Spring Meetings of AHRI. Since 2009, the refrigeration and air- conditioning sectors of the Vintaging Model have been updated multiple times. In 2012, an update to the large, medium, and small retail food end - uses had an impact on the projected service, leak, and new chemical demand, as well as disposal recovery. In addition, changes to the small commercial and residential unitary AC end - uses also affected the service demand of HCFC - 22. 

# Ap **pendix A:**  **Methodology Used to Calculate Projected**  **Serv icing Needs**  This appendix outlines the methodology used to calculate the projected servicing and new chemical need of AC, refrigeration, a nd fire suppression equipment using HCFC - 22 , HCFC - 123 and HCFC - 12 4 . This appendix contains two sections:  Section A.1 provides an overview of EPA’s Vintaging Model (EPA 2012), which was used to establish the estimates of units of equipment using HCFC - 22 and HCFC - 124 for servicing need beyond 2015 and HCFC - 123 for new equipment and servicing beyond 2015.  Section A.2 discusses the limitations to the servicing projections presented in this report. 

## A.1 **EPA’s Vintaging Model** EPA’s Vintaging Model was developed as a tool for estimating the annual chemical em issions from industrial sectors that have historically used ODS in their products. Em issions are es tim ated from the following end - use secto rs: 1) AirConditioning and Refrigeration; 2) Foams; 3) Aerosols; 4) Solvents; 5) Fire Extinguishing; and 6) Sterilants. Wi thin these sectors, there are over 60 independently modeled end - uses. The mo del requires information on the market growth for each of the end - uses, as well as a history and projection of the market transition from ODS to alternatives. As ODS are phased out, a percentage of the ma rk et share originally filled by the ODS is allocated to substitutes. The model, named for its method of trac king the emissions of annual “vintages” of new equipment that enter into service, is a “bottom - up” m odel. This me ans it models the consumption of controlled ozone - depleting substances and their substitutes based on: 1) Estimates of the quantity of equipm ent o r products sold, serviced, and retired or retrofitted each year, 27 and 2) The quantity of the chemical required to manufacture and/or ma intain the equipment. The model makes use of this market information to build an inventory of in - use stocks of equipment and quantities of ODS/ODS substitutes in each of the end uses.

27 All installations and retrofits and assumed to take place on January 1, at the start of the calendar year.The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 37 Em issions are estimated by applying annual leak rates, service emission rates, and disposal emission rates to consumption data for each vintage of equipment. Em issions from AC and refrigeration equipment are split into two categories: emissions during equipment lifetime and disposal emissions. The first category includes the amount of c hem ical leaked during equipment operation and the amount of c hem ical em itted during service. Consu mp tion required to service or refill equipment is driven by the need to replace such losses, and therefore, emissions during the lifetime o f equipment are equal to consumption for servicing (since it is assumed that all leaked refrigerant is eventually rep laced). Em issions, and therefore, consumption from leakage and servicing can be expressed as follows: **Es j**  **= (l a**  **+ l s**  **) × Σ**  **Qc j**  **- i+1**  **for i=1 →k**  Wh ere: Es = Em issions from Equipment Serviced. Emissions in year j from normal leakage and

servicing of equipment. la = Annual Leak Rate. Average annual leak rate during normal equipment operation

(expressed as a percentage of total chemical charge). ls = Service Leak Rate. Average leakage during equipment servicing (expressed as a

percentage of total chem ical charge). Qc = Quantity of Chemical in New Equipment. Total amount of a specific chemical used to

charge new equipment in a given year by weight. i = Counter, runs from 1 to lifetime (k). j = Year of emission. k = Lifetime. The average lifetime of the equipment. The assumptions used in this calculation range by equipment, refrigerant, and vintage, reflecting that as ne w technologies replace older ones, improvements in their leak, service, and disposal emission rates are assumed to occur. For the p urpose of this analysis, the following data from EPA’s Vintaging Model were compiled and summarized for the AC and refrigeration sector: 1) C onsumption for Servicing , which is equa l to the need to service (i.e., refill) existing equipment. These data are back - calculated using service and leak emissions because the quantity emitted during the lifetime of equipment drives the need to replace such losses. These estimates are further distinguished between consumption of virgin and recycled/reclaimed chemic al. The mo del assumes that a certain percentage of refrigerant, which varies by end - use, is recovered from discarded equipment. The model then assumes a “best- case” scenario in which all recovered and re - usable refrigerant re - enters the market. See Section A.2 for further discussion on this “recovery pool.” 2) Need for New Equipment, which is equal to the amount of chemical needed to fill new equipment. This estimate is further distinguished between consumption of virgin and recycled/reclaimed chemic al. 2) Number of Units of Equipment , which is equal to, for “year X” ’, the number of units existing in “year X- 1” plus the number of new units produced in “ year X” mi nus the number of units disposed in “year X” . For example: No. of Units in 1999 = No. of Units in 1998 + N ew Un its in 1999 – Units Disposed in 1999 Estimates from EPA’s Vintaging Model are often cross - checked with actual historical data from EPA’s ODS Tracking System, which tracks actual ODS production and consumption (including import and export) by U.S. com panies. The Model’s v irgin manufacture parameter is considered to be most com parable to the Montreal Protocol’s definition of consumption (i.e., production plus imports minus exports). In EPA’s Vintaging Model, the Virgin Manufacture parameter is calculate d to be any need for consumption (either for new equipment or servicing) that cannot be met through recycled or recovered ma terial; no distinction is made in the Vintaging Model between whether that need is met throughThe U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 38 dom estic manufacturing or imports. As shown in Figure A- 1, estimates from the model generally align to actual consumption from 1993 to 20 11 .

**Figure A -**  **1: Comparison of EPA ’s Vintaging Model Estimates for Virgin Manufacture** 

**and ODS Tracking System Data for HCFC -** **22 Consumption**

Table A- 1 presents the input assumptions used to develop the projections in this report. The loss rates represent the percent of the total charge that leaks in a given year plus the amount, on an annual basis, em itted at service, expressed as a percentage of total che mi cal charge. Because the amount lost from leaks and servicing is annualized, equipment is assumed to reach the end of its lifetime with a full charge. 28 EPA’s Vintaging Model then applies a “recovery rate,” which refers to the percent of total charge of the equipment that is recovered and reused at the time of disposal. These recovery rates represent averages, intended to capture the range of possible practices occurring at disposal. Growth rate assumptions are also provided in Table A- 1. The growth rates refer to the growth of the equipment market for each end - use as a whole and are not specific to the refrigerant. W hen the transition to different equipme nt and different refrigerants occur, the input assumptions are adjusted to account for these changes.

28 For the majority of equipment types, the assumption that equipment contains a full charge at the end of life is theoretically applicable. T o ensure proper and continual functioning of equipment, homeowners and businesses typically have their airconditioning and refrigeration systems serviced regularly. Technic ians will check these systems for leaks using proper techniques and if a loss of refrigerant is found, will refill the system to ensure it is functioning efficiently after repairing any lea king seals or damaged components. Note that this assumption may not be appropriate for smaller equipment types such as window units but is applied consistently for modeling purposes.



### 0 1000 2000 3000 4000 5000 6000 70001993199419951996199719981999200020012002200320042005200620072008200920102011**O D** **P W** **e i** **g h** **t e** **d M** **e t** **r i** **c T** **o n** **s** Vintaging Model Estimates ODS Tracking System Data

Source: EPA's ODS Tracking System, Vintaging Model (VM IO file_v4.4_11.6.12)The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 39 **Table A -**  **1: Input A ssumptions, Years 2015 to 2025**  **Current Refrigerant**  **Equipment Type and**

**Original ODS Refrigerant Charge**  **Size a**  **Loss**

**Rate Growth**  **Rate b**  **Recovery**

**Rate Lifetime** 

**(Years) Manufactured** 

**From AC Equipment**  HCFC - 22 HCFC - 22 Residential Unitary

A/C 3 14% 0.8% 35% 15 1992 - 200 5 HCFC - 22 HCFC - 22 Residential Unitary

A/C 5 1 4 % 0.8 % 35% 15 2006 - 2009 HCFC - 22 HCFC - 22 Small Commercial

Unitary AC 8 11% 0.8 % 40% 15 1992 - 200 9 HCFC - 22 HCFC - 22 Large Commercial

Unitary AC 15 10% 0.8 % 40% 15 1992 - 2009 HCFC - 22 HCFC - 22 Water & Ground

Source Heat Pumps 4 5% 0.8 % 57% 20 1992 - 2009 HCFC - 22 HCFC - 22 Dehumidifiers 0 1% 0.2% 50% 11 1985 - 2009 HCFC - 22 HCFC - 22 Packaged Terminal

Units 1 5% 0.8 % 35% 12 1992 - 2009 HCFC - 22 HCFC - 22 Window Units 1 1% 5.0% 50% 12 1985 - 2009 HCFC - 22 CFC - 12 School & Tour Buses 5 10% 2.6% 50% 12 1994 - 2006 HCFC - 22 HCFC - 22 Transit Buses 8 44% 2.6% 50% 12 1985 - 2008 HCFC - 22 CFC - 11 Centrifugal Chillers 700 14% 0.5% 80% 25 1991 - 1995 HCFC - 22 CFC - 11 Centrifugal Chillers 700 5% 0.5% 80% 25 1996 - 20 09 HCFC - 123 CFC - 11 Centrifugal Chillers 440 1% 0.5% 90% 2 5 1993 - Present HCFC - 22 CFC - 12 Centrifugal Chillers 721 8% 0.5% 80% 27 1991 - 1995 HCFC - 22 CFC - 12 Centrifugal Chillers 721 5% 0.5% 80% 27 1996 - 20 09 HCFC - 123 CFC - 12 Centrifugal Chillers 453 1 % 0.5% 90% 27 1993 - Present HCFC - 22 Reciprocating Chillers 230 6% 0.2% 80% 20 1993 - 1998 HCFC - 22 Reciprocating Chillers 230 1% 0.2% 80% 20 1999 - 2009 HCFC - 22 Screw Chillers 300 1% 0.5% 80% 20 1996 - 2009 HCFC - 22 Scroll Chillers 240 1% 0.5% 80% 20 1996 - 2009 HCFC - 22 R- 500 Chillers 926 11% 0.5% 80% 27 1991 - 1995 HCFC - 22 R- 500 Chillers 926 5% 0.5% 80% 27 1996 - 2009 HCFC - 123 R- 500 Chillers 582 1% 0.5% 90% 27 1993 - Present **Refrigeration Equipment** HCFC - 22 CFC - 12 Cold Storage <0.01 20% 2.5% 80% 20 1990 - 2009 HCFC - 22 HCFC - 22 Cold Storage <0.01 22% 2.5% 80% 20 1985 - 1992 HCFC - 22 HCFC - 22 Cold Storage <0.01 20% 2.5% 80% 20 1992 - 2009 R- 502 R- 502 Cold Storage < 0.01 25% 2.5% 80% 20 1985 - 1995 HCFC - 22 R- 502 Cold Storage <0.01 20% 2.5% 80% 20 1990 - 2009 HCFC - 22 CFC - 12 Large Retail Food 1,800 30% 0.8% 80% 18 1991 - 1999 HCFC - 22 CFC - 12 Large Retail Food 1,360 30% 0.8% 80% 18 2000 - 2009 HCFC - 22 R- 502 Large Retail Food 1,800 30% 0.8% 80% 18 199 0 - 1999 HCFC - 22 R- 502 Large Retail Food 1,800 30% 0.8% 80% 18 1995 - 1999 HCFC - 22 R- 502 Large Retail Food 1,360 30% 0.8% 80% 18 2000 - 2009 HCFC - 22 HCFC - 22 Large Condensing

Units (Medium Retail Food) 25 15% 0.9% 80% 20 1985 - 2009 R-402A HCFC - 22 Large Condensing

Units (Medium Retail Food) 25 15% 0.9% 80% 20 1995 - 2005 HCFC - 22 HCFC - 22 Small Condensing

Units (Medium Retail Food) 3 8% 0.9% 80% 20 1985 - 2009 R-402A HCFC - 22 Small Condensing

Units (Medium Retail Food) 3 8% 0.9% 80% 20 1995 - 2005The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 40 **Current Refrigerant**  **Equipment Type and**

**Original ODS Refrigerant Charge**  **Size a**  **Loss**

**Rate Growth**  **Rate b**  **Recovery**

**Rate Lifetime** 

**(Years) Manufactured** 

**From** R-401A HCFC - 22 Small Condensing

Units (Medium Retail Food) 3 8% 0.9% 80% 20 1995 - 2005 HCFC - 22 CFC - 12 Small Retail Food 1 8% 0. 8 % 35% 20 1990 - 2008 HCFC - 22 CFC - 11 Industrial Process

Refrigeration 952 10% 2.5% 80% 25 1991 - 2009 HCFC - 123 CFC - 11 Industrial Process

Refrigeration 598 5% 2.5% 90% 25 1992 - 2004 HCFC - 123 CFC - 11 Industrial Process

Refrigeration 598 5% 2.5% 90% 25 2005 - Present HCFC - 22 CFC - 12 Industrial Process

Refrigeration 992 10% 2.5% 80% 25 1991 - 2009 HCFC - 123 CFC - 12 Industrial Process

Refrigeration 623 5% 2.5% 90% 25 1992 - 2004 HCFC - 123 CFC - 12 Industrial Process

Refrigeration 623 4% 2.5% 90% 25 2005 - Present R-401A CFC - 12 Industrial Process

Refrigeration 850 5% 2.5% 90% 25 1995 - 1999 HCFC - 22 HCFC - 22 Industrial Process

Refrigeration 9,100 16% 2.5% 80% 25 1985 - 1992 HCFC - 22 HCFC - 22 Industrial Process

Refrigeration 9,100 12% 2.5% 80% 25 1992 - 2009 Source: VM IO File_v4.4_11.6.12 a Charge size presented in kilograms. Cold storage charge size presented in kilograms/cubic foot. b The growth rate applies to new consumption/virgin manufacture for products entering the market. For example, in the window un its market, any year’s consumption for new equipment is five percent greater than the previous year’s cons umption. Table A- 2 presents the assumptions used to model the transition from HCFC - 22 , HCFC - 123 , and HCFC 124 to alternatives for each end use. Only those end - uses that have been using HCFC - 22, HCFC - 123, or HCFC - 124 , or have in whole or in part transition ed to use HCFC - 22 , HCFC - 123 , HCFC - 124 , are shown. The first column of the table presents the HCFC - 22 , HCFC - 123 , and HCFC - 124 equipment types by the refrigerants that they originally used. The second column presents the refrigerants that enter the market an d are used in new equipment in place of HCFC - 22 , HCFC - 123 , or HCFC - 124 . 29 These refrigerants begin to enter the new- equipment market in the year presented in the third column and fully penetrate this ma rk et by

the date presented in the fourth column , after which they continue to make up that portion of the market. The final column indicates the percent of the HCFC - 22 , HCFC - 123 , and HCFC - 124 newequipment market that the given substitute refrigerant replaces by the transition end date. All transitions are ass um ed to occur linearly between the transition start and end dates. Each row represents a different vintage of equipment that can have different properties (e.g., charge size or leak rate) in addition to start date for the transition to the substitute , the end date to reach assumed market penetration , and assumed ma rk et penetration from the other vintages of equipment. By combining multiple transitions to different refrigerants and over different time periods, the Vintaging Model mimics actual, non - linear transitions that ma y occur.

29 These transition assumptions are for new equipment only; they do not imply that the original equipment was retrofitted to the alternative refrigerants.The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 41

**Table A -** **2: Transition to Alternatives A ssumptions of EPA** **’s Vintaging Model for**  **HCFC -** **22 ,**  **HCFC -**  **123 , and HCFC**  **- 124**  **Refrigeration and AC Equipment a** 

**1 2**  **3 4**  **5 Equipment Type and Original**  **ODS Refrigerant Substitute**  **Start Date End**  **Date b**  **Market**

**Penetration of Substitute**  **c** HCFC - 22 Residential Unitary AC R-410Ad 2000 2005 5% 2000 2006 5% 2006 2006 20% 2007 2010 20% 2010 2010 50% HCFC - 22 Small Commercial Unitary AC R-410A 1996 2000 3% 2001 2005 18% 2006 2009 8% 2009 2010 71% HCFC - 22 Large Commercial Unitary AC R-407C 2006 2009 1% 2009 2010 5% R-410A 2001 2005 5%

2006 2009 9% 2009 2010 81%
HCFC - 22 Water & Ground Source Heat Pumps R-407C 2000 2006 5% 2006 2009 3% 2009 2010 23% R-410A 2000 2006 5%

2006 2009 5% 2009 2010 41% HFC - 134a 2000 2009 2%

2009 2010 18% HCFC - 22 Dehumidifiers HFC - 134a 1997 1997 89% R-410A 2007 2010 11% HCFC - 22 Packaged Terminal Units R-410A 2006 2009 10% 2009 2010 90% HCFC - 22 Window Units R-410A 2008 2009 10% 2009 2010 90% CFC - 12 Tour Buses HFC - 134a 2006 2007 100% HCFC - 22 Transit Buses HFC - 134a 1995 2009 100% HCFC - 22 Trains HFC - 134a 2002 2009 50% R-407 2002 2009 50% CFC - 12 Cold Storage R-404A 1996 2010 75% R- 507A 1996 2010 25% HCFC - 22 Cold Storage R-404A 1996 2009 8% 2009 2010 68% R- 507A 1996 2009 3%

2009 2010 23% R- 502 Cold Storage R-404A 1996 2010 38% R- 507A 1996 2010 12% Other 1996 2010 50% CFC - 11 Industrial Process Refrigeration HFC - 134a 1995 2010 100% CFC - 12 Industrial Process Refrigeration HFC - 134a 1995 2010 15% R-404A 1995 2010 50% R-410A 1999 2010 20% R- 507A 1995 2010 15% HCFC - 22 Industrial Process Refrigeration HFC - 134a 1995 2009 2%The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 42

**1 2**  **3 4**  **5 Equipment Type and Original**  **ODS Refrigerant Substitute**  **Start Date End**  **Date b**  **Market**

**Penetration of Substitute**  **c** 2009 2010 14% R-404A 1995 2009 5%

2009 2010 45% R-410A 1999 2009 2%

2009 2010 18% R- 507A 1995 2009 2%

2009 2010 14%

CFC - 12 Large Retail Food R-404A 2000 2000 14% 2000 2009 4% 2001 2010 13% 2009 2010 29% 2010 2010 23% R- 507A 2000 2000 6%

2000 2009 0.4% 2001 2010 1% 2009 2010 4% 2010 2010 2% R-407A 2000 2009 1%

2001 2010 0.3% 2009 2010 2% 2010 2010 0.4%

R- 502 Large Retail Food R-404A 2000 2000 14% 2000 2009 4% 2001 2010 13% 2009 2010 29% 2010 2010 23% R- 507A 2000 2000 6%

2000 2009 0.4% 2001 2010 1% 2009 2010 4% 2010 2010 2% R-407A 2000 2009 1%

2001 2010 0.3% 2009 2010 2% 2010 2010 0.4% HCFC - 22 Large Condensing Units (Medium Retail Food) R-404A 1995 2000 30% 2008 2010 30% HFC - 134a 1993 2005 30%

2006 2006 10% HCFC - 22 Small Condensing Units (Medium Retail Food) R-404A 1995 2005 5% 2006 2006 25% 2008 2010 45% R- 507A 1995 2005 10%

2008 2010 15% CFC - 12 Small Retail Food HFC - 134a 1993 1995 85% R-404A 1993 1996 7.5%

2000 2009 7.5% R- 507A 1993 1996 2.5%

2000 2009 2.5%The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 43

**1 2**  **3 4**  **5 Equipment Type and Original**  **ODS Refrigerant Substitute**  **Start Date End**  **Date b**  **Market**

**Penetration of Substitute**  **c** CO2 2010 2010 5% CFC - 12 Transport HFC - 134a 1995 1999 100% R- 502 Transporte HFC - 134a 1993 1995 55% R-404A 1993 1995 45% HCFC - 22 Screw Chillers R-410A 2010 2020 36% R-407C 2000 2009 1%

2009 2010 9% 2010 2020 54% HCFC - 22 Scroll Chillers R-410A 2010 2020 36% R-407C 2000 2009 1%

2009 2010 9% 2010 2020 54% CFC - 12 Reciprocating Chillers R-410A 2010 2020 40% CFC - 11 Centrifugal Chillers HFC - 134a 2000 2010 100% CFC - 12 Centrifugal Chillers HFC - 134a 2000 2010 100% R- 500 Chillers HFC - 134a 2000 2010 100% Source: VM IO File_v4.4_11.6.12 a Interim transitions (e.g., from a CFC to HCFC -22 to HFCs) are not shown. For example, the retail food new- equipment market that originally used CFC - 12 first transitioned from CFC - 12 to R- 502 and then to HCFC -22 . Then, between 1995 and 2010, 83 percent of the HCFC -22 newequipment market is assumed to transition to R-404A, 13 percent to R- 507A., and the remaining 4% to R-407A . b The end date is January 1 of the year . Transitions are assumed to occur instantaneously on January 1. c The market penetration of the substitute represents the percent of the HCFC -22 new-equipment market that is replaced by the substitute refrigerant. d Multiple vintages of equipment are represented in this table (i.e. Two vin tages of R-4 1 0A equipment are represented separately. Each vintage has a different charge size and they reach their maximum market penetration a year apart). e The R- 502 transport refrigeration market transitions directly to HFC - 134a and R-404A. There is no interim transition to HCFC - 22 . f Only 13 SEER HCFC -22 equipment is modeled by the Vintaging Model. 

## A.2 **Limitations and Caveats** This analysis utilized the best data available from various sources. Nonetheless, when making projections several assumptions are required. The following caveats should be noted. **Recycled or Reclaimed Refrigerant** EPA’s Vintaging Model was used to determine the quantities of HCFC - 22 , HCFC - 123 , and HCFC - 124 from existing (recycled or reclaimed) sources that can meet post- 2015 servici ng needs. For a given year, the model assumes that a certain percentage of refrigerant, which varies by end - use, is recovered from discarded equipment, while the remainder is emitted . The model aggregates the quantities recovered but does not distinguish t he “pool” of refrigerant between quantities that are reclaimed versus those that are recycled. The model then assumes that the entire pool of recovered refrigerant re - enters the market within the same year. The model assumes that a ny additional need for refrigerant above th e estimated am ount recovered is met by virgin manufacture. The recovery pool and the remaining virgin manufacture are evaluated only at the most aggregate level, across all end - uses, and not at the end - use level, as the mo del does not dif

ferentiate between virgin and rec yc led refrigerant when calculating need for each end use. This model attribute reflects a more realistic scenario in that reclaimers are not likely to only sell back to the end - use market sector from which the used refrigerant originated; rather, reclaimed refrigerant can be retailed to the overall AC and refrigeration industry. Under this modeled approach, the model does not consider the quantity of refrigerant that companies send off for destruction after equipment is de commissioned. Although the quantities of destroyed refrigerant are very small, they are not subtracted from the recovered pool, so the quantity available for reuse may

be slightly overestimated in the model. Additionally, t he model does not account for anyThe U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 44 stockpiling of recovered refrigerant beyond a one - ye ar timeframe, as discussed in Section 4.3. To the extent that stockpiling has occurred over the last few years, the quantity of recovered refrigerant modeled as re - entering the market may be overestimate d in earlier years (i.e., when refrigerant is banked), and the quantity modeled as re - entering the market in later years may be underestimated (i.e., when the accumulated stockpile is accessed as a source). However, EPA has collected data on HCFC - 22 inventory from a handful of companies and is using that information to inform the 2015 - 2019 rulemaking. **Repairs with Dry**

**- Shipped Appliance Components**  Wh ile it is illegal to install new HCFC - 22 systems, HCFC - 22 components (e.g., condensing units, com pressors, line sets, etc.) that are shipped without a refrigerant charge are available for repairs of systems installed before 2010. The Vintaging Model assumes that components will continue to be available for usual repairs of existing equipment. A sensitivity analysis was performed to assess the potential impact of dry- shipped appliance components on Vintaging Model projections of HCFC - 22 servicing need . The analysis estimated that servicing need could be 7 to 11 pe rcent higher than the Vintaging Model projections when the installation of dry- shipped components is accounted for. Additional details of this analysis can be found in Appendix D. **Date of Shipment**  **versus Date of Installation of HCFC -**  **22 ,**  **HCFC -**  **123 , and HCFC** **- 124**  **Units** It is feasible and potentially common for some AC and refrigeration appliances to be ma nufactured, charged, shipped and/or purchased in one year and installed in another year. Such would be the case, for example, for units designated for constr uction projects that have received building code approval and entered into a binding contract in one year but are completed in some future year. The Vintaging Model relies on shipment data of new AC and refrigeration equipment to help estimate new units en tering the ma rk et for a given year. The model does not make adjustments to shipment data to reflect the date of installation since shipment data is the closest and best proxy to installation for the purposes of modeling. Thus, the model assumes the year of installation is the same as the year of shipment. Any equipment mo deled as “shipped” in 2014, for example, is therefore assumed to be part of the installed base in that ye ar . In summary , shipment date becomes the modeled installation date. For example, a residential unitary AC s ys tem shipped in 2009 would be in service for 15 years from that date, and would be retired in 2024. The model assumes that the entire fleet of 2014 HCFC - 123 units within a given end - use are being installed and retired in the same year, whereas, in reality some of these units may instead be installed a ye ar or two after shipment, starting their lifetime and servicing need a year or two after the shipment date, and hence, retiring a year or two after the retiremen t of the rest of the fleet. In this case , the model is not accurately reflecting the actual start and end date for servicing need for this subset of equipment. Instead, the model uses an average lifetime for each unique equipment type. This average is inte nded to account for units that are used for a few years less than the assumed useful life as well as those that are used well beyond their assumed useful life. Given the use of an average lifetime in the model, variations of a ye ar or two between shipment and installation date should fall within “normal” fluctuations in lifetime seen in actual equipment use. Additionally, the majority of HCFC consumption come s from residential and commercial refrigeration and AC equipment that have lifetimes of 15 years or longer . Thus, any such equipment entering the market after 2015 is assumed to remain in service beyond 2030, when all HCFC consumption will be phased out in the United States. **HCFC -**  **123 in Fire Suppression** Per an amendment to the Clean Air Act passed in December 2011, HCFC use in fire suppression in nonresidential applications can continue after 2015. The Vintaging Model does not yet reflect the am endm ent to section 605(a) of the Clean Air Act; however, a scenario was run to estimate the use of Halotron I —the most widely used fire suppression agent containing HCFC - 123—assuming production and consumption continued until December 31, 2019. Starting January 1, 2020, it is assumed that servicing needs remain stable at 210 MT, to reflect potential demand for ch arging portable fireThe U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 45 extinguishers with recycled HCFC - 123 based blends . Table A- 3 presents projected servicing need estimates for HCFC - 123. **Table A -**  **3: Projected HCFC -**  **123 Servicing Need**  **for Fire Suppression, 2015**  **- 2025, (Metric Tons**  ) **HCFC 2015**  **2016 2017**  **2 018**  **2019 2020**  **2025** HCFC - 123 190 200 20 0 2 10 21 0 210 210 These servicing need estimates were included in the analysis presented in the report.The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 46 

# Ap **pendix B: HCFC Projections by End**  **- Use**  This Appendix provides estimates of the projected installed base of HCFC equipment by end - use and the projected servicing need of HCFCs for AC and refrigeration equipment. Descriptions of end - uses are provided in Section 3 of the report. For the purpose of this analysis, data on HCFC blend consumption for servicing are div ided among the corresponding HCFC constituent(s) of that blend, according to the nom inal percent composition. However, to accurately portray the number of units containing HCFC - 22, blends are not disaggregated when presenting the number of units of equipment (i.e., a unit running on a blend containing HCFC - 22 counts as one unit). Table s B - 1 , B - 2 , and B - 3 present the number of units of equipment using HCFC - 22 , HCFC - 123 , and HCF C - 124 (or a blend containing these c hem icals ) respectively that are estimated to be in use in 2010, 2015, 2020, and 2025 . These estimates were developed based on EPA’s Vintaging Model, which takes into account recent input from stakeholders (EPA 20 12 ). Sections 3.1 and 3.2 provide an overview of these AC and refrigeration end - uses .

**Table B -**  **1: Estimated Number of HCFC**  **- 22 Units**  **in Operation a**  **Equipment Type 2010**  **2015 2020**  **2025** Window Units 76,181,000 43,444,500 4,102,700 - Packaged Terminal Units 2,478,800 1,355,100 123,100 - Residential Unitary AC 76,099,300 46,893,700 14,663,600 - Small Commercial Unitary AC 3,092,700 1,887,900 751,100 - Large Commercial Unitary AC 198,100 127,400 53,700 - Chillers 443,900 326,300 202,800 82,600 Dehumidifiers 1,282,100 670,200 - - Water & Ground Source Heat Pumps 1,393,700 1,104,800 695,800 247,500 Other Mobile AC (Bus & Train AC) 18,800 4,300 - - **Subtotal AC 161,188,400**  **95,814,200 20,592,800**  **330,100** Retail Food 2,112,000 969,100 461,870 142,1 0 0 Industrial Process Refrigeration 8,700 7, 500 5,6 00 3,5 0 0 **Subtotal Refrigeration 2,120,700**  **976, 60**  **0 467,5**  **0 0**  **145, 600**  **Total 163,309,100**  **96,790, 80**  **0 21,060,**  **30 0**  **475, 700**  a Cold Storage is not shown in this table because the model estimates this end - use based on cubic feet of storage, rather than number of units.

**Table B -** **2 : Estimated Number of**  **HCFC -**  **123 Units**  **in Operation**  **Equipment Type 2010**  **2015 2020**  **2025** Chillers 40,900 47,600 49,500 39,800 Industrial Process Refrigeration 9,200 12,600 14,300 12,000 Fire Suppression a 1,226,700 1,422,100 1,487,800 871,100 **Total 1,276,800**  **1,482,300 1,551,600**  **922,900** a Units of fire suppression equipment does not reflect units of new equipment charged with recycled HCFC - 123 starting in 2020 . **Table B -**  **3 : Estimated Number of**  **HCFC -**  **124 Units**  **In Operation**

**Equipment Type 2010**  **2015 2020**  **2025** Industrial Process Refrigeration 170 170 140 - Medium Retail Food 27, 70 0 27, 20 0 18, 80 0 - **Total 27,8**  **0 0**  **27,400 18,900**  **0**The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 47 Table B -4 presents the metric tons of HCFC - 22 estimated to be needed to service AC and refrigeration equipment in 2010, 2015, 2020, and 2025. Table B - 5 presents the metric tons of HCFC - 123 estimated to be needed to service and charge new and existing AC an d refrigeration equipment in 2010, 2015, 2020, and 2025 . Table B - 6 presents the metric tons of HCFC - 124 estimated to be needed to service refrigeration equipment in 2010, 2015, 2020, and 2025.

**Table B -** **4 : Projected**  **HCFC -** **22 Servicing Need**  **(Metric Tons) Equ**  **ipment Type 2010**  **2015 2020**  **2025** Window Units 270 160 <50 - Packaged Terminal Units 90 <50 <50 - Residential Unitary AC 37,900 24,400 9,500 - Small Commercial Unitary AC 2,6 0 0 1,600 600 - Large Commercial Unitary AC 300 190 80 - Chillers 3, 30 0 1,300 720 310 Dehumidifiers <50 <50 - - Water & Ground Source Heat Pumps 290 230 140 50 Other Mobile AC (Bus & Train AC) 80 <50 - - **Total AC 44,800**  **27,900 11,100**  **360** Cold Storage 1, 10 0 830 570 340 Retail Food 14, 70 0 10,200 5,500 1,300 Industrial Process Refrigeration 8,9 0 0 7,200 5,400 3,500 **Total Refrigeration 24,700**  **18,200 11,400**  **5,200 Total**  **69,400 46,100**  **22,500 5,500**  Note: Totals do not sum due to independent rounding

**Table B -**  **5 : Projected**  **HCFC -**  **123 Servicing Need**  **(Metric Tons )**  **Equipment Type 2010**  **2015 2020**  **2025** Chillers 42 0 1 , 2 0 0 220 180 Industrial Process Refrigeration 2 60 770 370 290 Fire Suppression 16 0 190 210 210 **Total 8**  **50 2,200**  **800 680** 

**Table B -**  **6 : Projected**  **HCFC -**  **124 Servicing Need**  **(Metric Tons )**  **Equipment Type 2010**  **2015 2020**  **2025** Industrial Process Refrigeration 2 2 2 - Medium Retail Food 2 2 1 - **Total 5**  **5 4**  **-** Note: Totals do not sum due to independent roundingThe U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 48 

# Ap **pendix C: Changes to the Vintaging Model** Table C - 1 summarizes the changes that have been made to EPA’s Vintaging Model and the HCFCs affected by the alteration since the 2009 Service Tail Report. Changes were made to the model based on industry research and feedback.

**Table C**  **- 1**  **: Changes Made to EPA** **’s Vintaging Model (Since 2009) End Use**  **Change (s)**  **Made HCFCs**  **Affected** Large Retail Food a Increased 1985 stock assumptions Charge size reduced Distributed systems and Secondary Loop Systems (SLS) were introduced (reduced charge sizes) Increased lifetime from 15 years to 17.5 years Increased disposal loss rate for DX (20%) and Distributed (18.5%) and decreased disposal loss rate for SLS (14 %) New refrigerants added to end - use (R-402A, R-422A, R-422D, R-407A, R-408A [ R-402A and R-408A blend s contain HCFC - 22]) HCFC - 22

Medium Retail Food a End - Use was split into two end - uses ( large condensing units and small condensing units) Decreased 1985 stock assumptions Additional refrigerant blends were added (R-401A [containing HCFC - 22 and HCFC - 124], R-402A, HFC - 134a) Large condensing units ha ve a larger annual leak rate (increased from 6%to 13 %) HCFC - 22, HCFC - 124

Small Retail Food a Increased 1985 stock assumptions Decreased leak and service rate HCFC - 22 Small Commercial Unitary AC Increased original 1985 stock assumptions HCFC - 22 Large Commercial Unitary AC Decrease d original 1985 stock assumption HCFC - 22 Residential Unitary AC Increased original 1985 stock assumptions Removed transitions to R-407C (all equipment transitions from HCFC - 22 to R-410A) Increased service loss rate (10%) HCFC - 22

a ICF, 2011.The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 49 

# Ap **pendix D: Sensitiv**  **ity An**  **al ys**  **es** Although EPA’s assumptions are continually updated to improve and refine the accuracy of the model , future servicing need for HCFC - 22 is affected by outside factors that may not be fully reflected . The extent to which the market price of HCFC - 22 fluctuates and affects usage patterns and transitions and how HCFC allocations in recent years affect future servicing needs are two examples of market influence that is not captured in the current assessment . This Appendix presents analyses performed to determine the effect that different assumptions may have on HCFC - 22 service need . The following sensitivity analyses were considered individually (i.e., the effects on HCFC - 22 servicing need resulting from e ach analysis are not additive or cumulative) : 

###  Sm aller s ystem charge sizes; 

###  Lower e quipment loss rates; 

###  Earlier transitions to alternatives; and 

###  Longer equipment lifetimes due to repairs using d ry- shipped condensing units . 

## D. **1 Smaller**  **System Charge Size**  This sensitivity analysis explores the impact on servicing need of a smaller charge size in residential unitary AC equipment. Residential unitary AC accounts for approximately 50 percent of the total servicing need across all refrigeration and AC end - uses for 2015 to 2019. This end - use represents such a large portion of the total servicing need for HCFC - 22 in refrigeration and AC equipment due in part to its high installed base, larger equipment charge sizes, long lifetimes, and high loss rates. A large num ber of residential unitary AC units containing HCFC - 22 will continue to be in use through 2023, and they are projected to require a significant amount of HCFC - 22 to meet their servicing need . In 2001, the U.S. Department of Energy (DOE) set a stricter se asonal energy efficiency ratio (SEER) standard for residential unitary ACs and heat pumps. The minimum efficiency standard of residential unitary ACs and heat pumps was raised by 30 percent to a 13 SEER for all such units manufactured for sale on or after January 23, 2006 (DOE 2001; DOE 2004). These increased SEER requirements are reflected in th is report , although earlier SEER requirements are not explicitly reflected. As shown in the Table D - 1 , the EPA currently assumes that the 13 SEER vintage of HCFC - 22 residential unitary AC equipment uses a charge size of approximately 4.8 kg. **Table D**  **- 1**  **: Charge Size, Loss Rate, and Lifetime for HCFC**  **- 22 Residential A** **C Equipment**

**End -**  **Use Original** 

**Residential Unitary AC 13 SEER**  **Residential Unitary AC** Charge Size (kg) 3.4 4.8 Annual Loss Rate 13.6% 13.6% Lifetime (years) 15 15 Manufactured From 1992 - 2005 2006 – 2009 This analysis examines the potential effects on service need of a smaller charge size of 4 kg for HCFC - 22 13 SEER residential unitary AC equipment. This change results in a 2 to 7 percent decrease in total HCFC - 22 service need across all refrigeration and AC end - uses between 2015 and 2023, as shown in Table D - 2 . After 2023, all HCFC - 22 residential unitary AC equipment is modeled as having reached end of- life, so there is no longer servicing need for the end - use.The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 50 **Table D**  **- 2**  **: HCFC -** **22 Ser vice**  **Need for Residential AC from**  **Smaller 13 SEER Charge Size,** 

**2015 -**  **2025 End**  **- Use**  **2015 2016**  **2017 2018**  **2019 2020**  **2021 2022**  **2023 2024**  **2025** Resid ential Unitary AC VM Baseline 24, 400 21,70 0 18, 900 16,0 00 1 3,000 9, 500 6, 500 3, 900 1, 800 - -

Lower Charge 23,2 00 20,5 00 17,6 00 14,7 00 1 1,600 8,000 5,4 00 3, 300 1, 500 - - **Total VM**  Baseline **46,100 41,600**  **36,700 32,300**  **27,700 22,500**  **17,900 13,700**  **10,100 6,900**  **5,500**

**Lower Charge**  **45,000 40,400**  **35,500 31,000**  **26,300 21,000**  **16,800 13,100**  **9,800 6,900**  **5,500 Percent Decrease in**  **Total HCFC -** **22 Need**  **(All Ref /** **AC End Uses) 2%**  **3% 3%**  **4% 5%**  **7% 6%**  **5% 3%**  **- -**  Note: Totals may not sum due to independent rounding . 

## D. **2 Lower Equipment Loss Rate**  This sensitivity analysis explores the impact on servicing need of a lower loss rate for residential unitary AC, large and medium retail food refrigeration, and cold storage units. Wi th the price of HCFC - 22 increasing, feedback from stakeholders has suggested that service technicians may now be mo re careful with the refrigerant, resulting in lower loss rates than those estimated in th is report . Between 2015 and 2021, service need from residential unitary AC, large retail food refrigeration, medium retail food refrigeration (large condensing units), and cold storage together are projected to account for approximately 70 to 80 percent of the total service need across all refrigerati on and AC end - uses; by 2025, this proportion drops to 30 percent of total need . 30 These four end - uses represent a large portion of the total servicing need for HCFC - 22 in refrigeration and AC equipment due in part to their high installed base, larger equipm ent charge sizes, long lifetimes, and high mo deled loss rates. A large number of units containing HCFC - 22 within these end - uses will continue to be in use through 2025, and they are expected to require a significant amount of HCFC - 22 to meet their servicin g need . The annual loss rates for these end - uses ( as mo deled in the Vintaging Model ) a re shown in Table D - 3 . The annual loss rate is equal to the annual leak rate plus the annual emission rate from servicing. **Table D**  **- 3**  **: An**  **nual Loss Rate and Lifetime for HCFC**  **- 22**  **Residential A C,**  **Large Retail Food**  **Refrigeration, Me**  **dium Retail Food Refrigeration (Large Condensing Units) ,**  **and Cold Storage**  **Equipment End**  **- Use**  **HCFC -** **22 Equipment Charge Size (kg)**  **Lifetime (years)**  **HCFC -** **22 Equipment**

**Annual Loss Rate** Residential Unitary AC 3 - 5 15 14% Large Retail Food 1,360 - 1,800 18 30% Medium Retail Food (Large Condensing Units) 25 20 15% Cold Storage <0.01 a 20 -25 20% a Cold storage charge size presented in kilograms/cubic foot This analysis examines the potential effects of a lower loss rate for HCFC - 22 equipment on service need , by assuming that residential unitary AC, large retail food refrigeration, medium retail food refrigeration (large condensing units), and cold storage u nits undergo annual leak tightening beginning in 2012. The following specific assumptions are made:

 Residential Unitary AC: Annual loss rate will decline by 1 percentage point per year until the loss rate equals 10 percent.

30 Ref/AC end - uses include window units, packaged -terminal AC, residential unitary AC, small commercial unitary AC, large commercial unitary AC, chillers, dehumidifiers, water & ground source heat pumps, other mobile AC, cold storage, retail food, refrigerated transport, and industrial process refrigeration.The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 51  Large Retail Food: Annual loss rate will decline by 5 percentage points so that the loss rate equals 25 percent .  Medium Retail Food (Large Condensing Units): Annual loss rates will decline by 1 percentage point per year until the loss rate equals 10 percent. 

###  Cold Storage: Annual loss rate will decline by 1 percentage point per year until the loss rate equals 15 percent 

### . These changes result in a 10 to 23 percent decrease in total HCFC - 22 service need across all refrigeration and AC end - uses between 2015 and 2 025, as shown in Table D -4 . **Table D**  **- 4**  **: HCFC -** **22 Service Need**  **for Residential AC, Large**  **Retail Food Refrigeration, Me**  **dium Retail Food (Large Condensing Units)**  **, and**  **Cold Storage from Lower A nnual Loss Rates,**  **2015 -**  **2025 End**  **- Use**  **2015 2016**  **2017 2018**  **2019 2020**  **2021 2022**  **2023 2024**  **2025** Residential Unitary AC 31 VM

Baseline 24, 400 21,70 0 18, 900 16,0 00 1 3,000 9, 500 6, 500 3, 900 1, 800 - - Lower Loss 17,200 15,300 13,300 11,300 9,200 6,700 4,600 2,700 1,200 - - Large Retail Food VM

Baseline 9,1 00 8,2 00 7,2 00 6, 500 5, 800 4,9 00 4, 200 3, 400 2,6 00 1, 900 1,1 00 Lower Loss 6,000 5,400 4,800 4,300 3,800 3,300 2,700 2,200 1,700 1,200 700 Medium Retail Food (Large Condensing Units) VM

Baseline 9 00 8 00 7 00 700 600 5 00 500 40 0 3 00 300 200 Lower Loss 700 600 500 4 00 400 400 3 00 300 2 00 200 1 00 Cold Storage VM

Baseline 8 00 800 7 00 700 6 00 600 5 00 500 4 00 400 3 00 Lower Loss 700 60 0 5 00 500 500 4 00 400 400 3 00 300 300 **Total VM** 

Baseline **46,100 41,600**  **36,700 32,300**  **27,700 22,500**  **17,900 13,700**  **10,100 6,900**  **5,500 Lower**  **Loss 35,400**  **31,900 28,300**  **25,000 21,600**  **17,700 14,300**  **11,200 8,400**  **6,100 5,000**  **Percent Decrease in Total HCFC**  **- 22**  **Need (All Ref**  **/ AC End Uses)**  23% 23% 23% 23% 22% 21% 20% 19% 16% 12% 10% Note: Totals may not sum due to independent rounding . 

## D**. 3**  **Earl ier**  **Equipment Transitions to Alternatives**  This sensitivity analysis explores the impact on servicing need of an earl ier transition of HCFC - 22 residential unitary AC, retail food refrigeration, and IPR equipment to alternative refrigerants . Of total HCFC - 22 service need from 2015 to 2020, residential unitary AC, retail food refrigeration, and industrial process refrigeration (IPR) together account for approximately 90 percent. 32 As the price of HCFC - 22 increased and as equipment reached the en d of its useful life, feedback from stakeholders indicates that retrofits and s ys tem replacements may have occurred more rapidly than modeled in this report . New residential unitary AC equipment completed the transition from HCFC - 22 to R-410A as of 2010, due to the ban on the use of virgin HCFC - 22 to service new refrigeration and air- conditioning equipment. Although no new residential AC systems are manufactured today using HCFC - 22, th is report assumes 31 Since the Vintaging Model assumes all new instal lations take place on January 1, the final HCFC - 22 residential unitary AC installations are modeled as taking place on January 1, 2009. Thus, the 15 year modeled lifetime expires at the end of 2023 a nd so HCFC - 22 servicing demand is modeled at zero startin g in 2024. 32 Refrigeration and AC end - uses include window units, packaged -terminal AC, residential unitary AC, small commercial unitary AC, large commercial unitary AC, chillers, dehumidifiers, water & ground source heat pumps, other mobile AC, cold storag e, retail food, refrigerated transport, and industrial process refrigeration.The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 52 that an estimated 50 percent of the residential unitary AC market in the United States was using HCFC 22 through 2009 . As a result, servicing need for HCFC - 22 is modeled for another 15 years—through the end of 2023 —the full 15 year lifetime of these units. A significant portion of retail food refrigeration, which consists of large direct expansion (DX) systems, large condensing units, small condensing units, and stand - alone units, were also using HCFC - 22 or blends containing HCFC - 22 up until 2010; however, transitions away from HCFC - 22 to other refrigerants and refrigerant blends (e.g., HFC - 134a, R- 507, and R-404A) are mo deled as early as 1993. In the retail food sector, industry contacts , especially distributors, are suggesting that HCFC - 22 sales have dropped off significantly in recent years, and that retrofits or system replacements are undertaken more frequently. Wh ile historical HCFC - 22 use in IPR s ys tems was somewhat limited — HCFC - 22 systems only accounted for approximately 10 - 15 percent of the total IPR market, some HCFC - 22 units continued to be ma nufa ctured until 2010 (as modeled in th is report ). These units have significant charge sizes and a lifetime of approximately 25 years, which contribute to the high service need for these units beyond 2015. This analysis examines the potential effects of early retirement of HCFC - 22 equipment on service need , by assuming that 20 percent of residential unitary air- conditioning , retail food refrigeration , and industrial process refrigeration equipment are retired 5 years earlier tha n th is report assumes, beginning in 2010 (e.g., 20 percent of equipment that would have retired in 2015 is being retired in 2010 instead) . These changes result in a 9 to 1 4 percent decrease in HCFC - 22 service need between 2015 and 2025, as shown in T able D - 5 . **Table D**  **- 5**  **: HCFC -** **22 Service Need**  **for Residential AC, Retail Food Refrigeration, and Industrial**

**Process Refrigeration from Early Retirement, 2015**  **- 2025**  **End -**  **Use 2015**  **2016 2017**  **2018 2019**  **2020 2021**  **2022 2023**  **2024 2025**  Residential VM Baseline 24, 400 21,70 0 18, 900 16,0 00 1 3,000 9, 500 6, 500 3, 900 1, 800 - -

Early Transition 21,4 00 18, 700 15, 900 13, 200 10, 400 7, 600 5, 200 3,1 00 1,40 0 - - Retail Food VM Baseline 10,20 0 9, 200 8,0 00 7,2 00 6,40 0 5,5 00 4, 700 3,8 00 3,000 2, 200 1,3 00

Early Transition 9,300 8,300 7,200 6,400 5,600 4,700 3,800 3,100 2,400 1,700 1,100 IPR VM Baseline 7, 200 6, 800 6, 400 6,000 5,70 0 5, 400 5,000 4,6 00 4, 300 3, 900 3, 500

Early Transition 6, 800 6,40 0 6,0 00 5, 700 5, 300 5,000 4, 600 4,2 00 3, 900 3, 500 3, 100 **Total VM** 

**Baseline 46,100**  **41,600 36,700**  **32,300 27,700**  **22,500 17,900**  **13,700 10,100**  **6,900 5,500**  **Early Transition**  **41,800 37,300**  **32,600 28,300**  **23,900 19,400**  **15,400 11,800**  **8,700 6,100**  **4,900 Percent Decrease in Total**  **HCFC -** **22 Need**  9% 10% 11% 13% 14% 14% 14% 14% 13% 12% 12% Note: Totals may not sum due to independent rounding . 

## D**. 4**  **Longer E** **quipment L**  **ifetimes D**  **ue to R** **epairs U**  **sing D** **ry**

  ** S****hipped C** **ondensing U**  **nits** This sensitivity analysis explores the impact on servicing need of repairing residential unitary AC s ys tems with dry- shipped condensing units ( CUs ) . Although new HCFC - 22 s ys tems were banned in 2010, replacement dry- shipped CUs can be used for repairing systems, potentially extending the lifetime of the AC unit (and servicing need ). This analysis assumes existing residential unitary AC units using HCFC - 22 are repaired with dry- shipped CUs. Ta ble D - 6 shows the percentage of new shipments that EPA assumes are HCFC - 22 CUs instead of R-410a CUs. **Table D**  **- 6**  **: As**  **sumptions f** **or Percentage of New**  **CU Shipments Going to HCFC**  **- 22 Repairs**  Year 2010 2011 2012 2013 2014 2015 2016 2017 2018 Percentage of New Shipments 5% 20% 15% 10% 10% 5% 5% 5% 0%The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 53 The analysis further assumes that repairing systems with dry- shipped CUs extends the equipment lifetime by 10 years. Table D - 7 shows the resulting increase in need in the residential unitary AC end - use and the percent increase in service need compared to total need from all refrigeratio n and air- conditioning end - uses associated with increasing equipment lifetimes by 10 years with dry- shipped CUs. This change results in a 7 to 11 percent increase in HCFC - 22 service need between 2015 and 2025. **Table D**  **- 7**  **: A dditional HCFC**  **- 22**  **Need in Residential Unitary A** **C from Dry -**  **Shippe d CUs**  **, 2015 -** **2025 End**  **- Use**  **2015 2016**  **2017 2018**  **2019 2020**  **2021 2022**  **2023 2024**  **2025** Baseline Servicing Need for Residential Unitary AC 24, 400 21,70 0 18, 900 16,0 00 1 3,000 9, 500 6, 500 3, 900 1, 800 - - Additional Modeled Servicing Need for Residential Unitary AC 3,7 00 3,9 00 4,1 00 2,7 00 2,7 00 2, 600 1, 900 1,30 0 9 00 600 400 **Total Residential Unitary AC**  **Servicing Need 28,1**  **00 25,6**  **00 2**  **3,000 18,**  **800 15,7**  **00 12,**  **100 8,30**  **0 5,**  **200 2,**  **700 600**  **400 Increase in Total**  **Need for All**  **HCFC -**  **22 Ref/AC Servicing**  **8% 9%**  **11% 8%**  **10% 11%**  **10% 10%**  **9% 8%**  **7%** Note: Totals may not sum due to independent rounding.The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 54 

# Ap **pendix E**  **: HCFC**  **- 22 Inv** **entory Estimate** In August 2013 , EPA asked questions of up to nine companies about their HCFC - 22 inventory and sales. Under section 114(a) of the Clean Air Act, for the purpose of carrying out any provision of the Act , EPA has the authority to ask any person who is subject to any requirement of the Act to establish and maintain such records, make such reports, and provide such other information as the Administrato r may reasonably require. Many stakeholders encouraged EPA to use this authority to gather data on HCFC - 22 inventory levels in particular. EPA used the data received in response to its section 114 request to substantiate what the agency had already heard from many industry representatives: HCFC - 22 inventory is still high, and potentially higher than the agency had previously estimated in the fall of 2011. Concurrent with the 2012 - 2014 Proposed Rule, EPA published Analysis of HCFC – 22 Servicing Needs in th e U.S. Air Conditioning and Refrigeration Sector: Additional Considerations for Estimating Virgin Demand (“Adjustment Memo”), which stated that EPA believed HCFC - 22 inventory was between 22,700 and 45,400 MT. Based on inventory data from a limited number o f companies as of December 31, 2012, as well as other information received by the agency during the development of this proposed rule, EPA knows HCFC - 22 inventory is higher than its previous estimate. Given that inventory at the end of 2012 was higher t han 45,400 MT, EPA expects that a significant am ount of HCFC - 22 servicing need in 2015 - 2019 can be met by existing stocks. Since HCFC - 22 inventory is quite large, and may even grow in 2013 and 2014, the preamble to the 2015 - 2019 Proposed Rule states that E PA is proposing to account for up to 10,000 MT of inventory drawdown each year as it considers an appropriate HCFC - 22 consumption allocation.The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 55 

# References Airgas. 2006. Personal communication between Lauren Flinn, ICF International, and Bob Mueller, Dire ctor, Utility & CPI Industries , Airgas . August 2006 . The Alliance for Responsible Atmospheric Policy . 2006 . Comment submitted in response to EPA’s Notice of Data Availability (NODA, 70 FR 67172), November 4, 2005 . EDocket ID Number, OAR- 2003 - 0130, Docume nt ID No. 0172, 0174, January 19, 2006, January 26, 2006. Am erican Pacific. 2013. Personal communication between Derina Man, ICF International , and Jeff Gibson, American Pacific. April 2013. Am trak . 2005 . Em ail correspondence between Iliriana Mushkolaj , ICF Consulting and Madina Alharazim, Am trak . July 2005 . ARI. 2005. Personal communication and transcribed correspondence between Lauren Flinn, ICF Consulting and Karim Amrane, Air- Conditioning and Refrigeration Institute (ARI) . March to June 2005 . Ar ke ma . 2009. Comment submitted in response to EPA’s Notice of Data Availability (NODA, 40 FR Part 82) . December 23, 2008. EDocket ID Number, OAR- 2008 - 0496, Document ID No. 01 11. 1, March, 9 , 200 9. Badger/Kidde. 2013. Personal communication between Derina M an, ICF International, and Tom Lucier, Badger/Kidde. March 2013. Carrier Corporation. 2005a. Personal communication and transcribed correspondence between Lauren Flinn, ICF Consulting and Fred Keller, Carrier Corporation. June 2005 . Carrier Corporation . 2005b . Personal communication between Iliriana Mushkolaj, ICF Consulting and Chris Repice, Carrier Corporation . June 2005. Cold Ships . 2009. Personal communication between Lauren Flinn, ICF International and Gerald Donovan, Cold Ships. October, 2009. DOE. 2012. Energy Saver: Central Air Conditioning. Available at: http://energy.gov/energysaver/articles/central - air- conditioning . Accessed February 2013. DOE. 2011. Federal Registe r. “Energy Conservation Program: Energy Conservation Standards for Residential Furnaces and Residential Central Air Conditioners and Heat Pumps; Direct Final Rule.” Volume 76, Number 123. June 27, 2011. 10 CFR Part 430. Available online at http://www.regul ations.gov/#!documentDetail;D=EERE - 2011 - BT - STD - 0011 - 0001 DOE. 2004. Department of Energy Press Release . “Energy Department Wi ll Enforce 13 SEER Air Conditioner Standard.” Number R- 04 - 064 . April 2, 2004. DOE. 2001 . Federal Register . “Consumer products; energy conservatio n program: Central air conditioners and central air conditioning heat pumps — Energy conservation standards; Final Rule.” Volume 66, Number 14 . January 22, 2001 . 10 CFR, Part 430 . Available at http://frwebgate.access.gpo.gov/cgi - bin/getdoc. cgi?dbname=2001_register&docid=01 - 1790 -filed EPA . 2013. Summary

of Refrigerant Reclamation 2000 - 2011. Available at < http://www.epa.gov/ozone/title6/608/reclamation/recsum.pdf> . Accessed January 2013. EPA . 2012. U.S. EPA Vintaging Model. Version VM IO_v4. 4_11.6.12. EPA. 2011. Federal Register. “Protection of Stratospheric Ozone: Adjustments to the Allowance SystemThe U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 56 for Controlling HCFC Production, Import, and Export.” Vol. 76, No. 151 . Friday , August 5, 2011. 40 CFR Part 82. Available online at http://www.gpo.gov/fdsys/pkg/FR- 2011 - 08 - 05/pdf/2011 - 19896.pdf . EPA. 2009. “ Protection of Stratospheric Ozone: Adjustments to the Allowance System for Controlling HCFC Production, Import, and Export .” Vol. 74, No. 239 . T uesday, December 15, 2009. 40 CFR Part 82. Available at http://www.gpo.gov/fdsys/pkg/FR- 2009 - 12 - 15/pdf/E9 - 29569.pdf . EPA . 2007. HCFC Phase out Schedule. Available at http://www.epa.gov/ozone/title6/phaseout/hcfc.html . Accessed December 2007. EPA. 2006. Global Mitigation of Non - CO2 Greenhouse Gases. EPA Report 430 - R- 06 - 005. Wa shington, DC: U.S. Environmental Protection Agency, Office of Atmos pheric Programs. EPA . 2004a. Federal Register . “Protection of Stratospheric Ozone: Refrigerant Recycling: Substitute Refrigerants; Final Rule.” Volume 69, Number 49 . March 12, 2004 . 40 CFR, Part 82 . Available online at http://www.epa.gov/ozone/title6/608/regulations/69fr11946.pdf. EPA . 2004b. “Analysis of Costs to Abate International Ozone - Depleting Substance Substitute Emissions.” Office of Air and Radiation, U.S. Environmental Protection Agency, Report No. EPA 430 - R- 0 4 - 006 . Wa shington, DC, June 2004 . EPA . 2003a . Federal Register . “Protection of Stratospheric Ozone: Allowance System for Controlling HCFC Production, Import and Export .” Volume 68, Number 13 . January 23, 2003 . 40 CFR, Part 82 . Available at http://www.ep a.gov/ozone/title6/phaseout/68fr2819.pdf. EPA . 2003b. “Regulatory Im pact Analysis: The Substitutes Rec yc ling Rule (Section 608 of the Clean Air Act Amendments of 1990).” September 16, 2003 . U.S. EPA, Global Programs Division, Office of Air and Radiation. FMI . 1995 . Guidelines for the Use of Alternative Refrigerants in the Supermarket . The Education and Research Departments, Food Marketing Institute . Released September 1995. Garry, M. 2012. SN Refrigeration Survey: HCFC- 22 Still Widely Used. Supermarket N ews. October 12, 2012. Available online at http://supermarketnews.com/technology/sn - refrigeration - survey- HCFC - 22 - still widely- used Grey hound . 2005 . Personal communication between Iliriana Mushkolaj, ICF Consulting and Mario Nava, Grey hound . June 2005. Am erican Pacific . 2008. Halotron Product Information. Available online at http://www.halotroninc. com /halotron1.php. Accessed April 2008. HARDI . 2004. The Status of Refrigerant 410A For New A/C Equipment. Heating, Air- conditioning, & Refrigeration Distrib utors International (HARDI), Refrigeration Systems Council Report to Industry. March 15, 2004. Hill Phoenix . 2009. Personal communication between Emily Herzog, ICF International and Scott Martin, Hill Phoenix. May 2009. Hill Phoenix . 2005. Personal comm unication and transcribed correspondence between Lauren Flinn, ICF Consulting and Scott Martin, Hill Phoenix . February and June 2005 . Home Energy Center . 2006 . Personal communication between Charlotte Coultrap - Bagg, ICF Internationa l and Steve W oolery, H om e Energy Center . August 23, 2006. Hughes Associates Inc. 2012. Personal communication between Derina Man, ICF International, and Dan Verdonik. April 5, 2012.The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 57 Hussmann/Ingresoll Rand . 2009. Personal communication between Julia Forge, ICF International , a nd Bryan W are, Hussman/Ingersoll Rand. July 2009. ICF International. 2012. Proposed Approach: Other HCFCs beyond 2014. Memorandum. EPA. ICF International. 2011. Revised Analysis of HCFC - 22 Servicing Needs in the U.S. Refrigeration and Air Conditioning Sector: Additional Considerations for Estimating Virgin Demand. Memorandum. EPA. Johnson Controls, 2009. Personal communication between Lauren Flinn, ICF International and Chris Forth, Johnson Controls. J.P. Morgan, 2011. 2011 HVAC Review and Outlook. North America Equity Research. November 11, 2011. Kysor/W arren . 2009. Personal communication between Emily Herzog, ICF International , and Travis 0 Lum pk in, Kysor/W arren. May 2009. Motorcoach Training . 2005 . Personal communication and transcribed correspondence between Lauren Flinn, ICF Consulting and Joe Pemberton, Motorcoach Training . June to July 2005. National Refrigerants, Inc . 2006 . Comments submitted in response to EPA’s Notice of Data Availability (NODA, 70 FR 67172), November 4, 2005 . EDocket ID Number, OAR- 2003 - 0130, Document ID No. 0170, 0170.1, January 2, 2006. Shecco. 2012. 2013: Natural Refrigerants Market Growth for North America. Available onlin e at: http://www.shecco.com/files/the_guide_2013 - am erica.pdf Skaer, Mark . 2007 . Average SEERs Rise in Residential Sector . Air Conditioning, Heating & Refrigeration News . September 10, 2007. UNEP. Report of the Technology and Economic Assessment Panel: Decision XXIV/7 Task Force Report, Additional Information to Alternatives on ODS (volume 2), September 2013, p.113. UNEP . 2003a. Report of the Technology and Economic Assessment Panel of the Montrea l Protocol, TEAP HCFC Task Force, May 2003. Ozone Secretariat, United Nations Environment Programme . Available online at: http://ozone.unep.org/teap/Reports/Other_Task_Force/HCFC03R1.pdf . UNEP . 2003b. Handbook for the International Treaties for the Protec tion of the Ozone Layer. Sixth Edition . United Nations Environment Programme, Ozone Secretariat . Available online at http://www.unep.org/ozone/Handbook2003.shtml. UNEP . 2000 . The Montreal Protocol on Substances that Deplete the Ozone Layer . Ozone Secretar iat . United Nations Environment Programme . Available online at http://ozone.unep.org/pdfs/Montreal Protocol2000.pdf . United States Congress. 2011. National Defense Authorization Act for Fiscal Year 2012 . 112 Cong., 1 sess. Cong. Bill. Available online at <http://www.gpo.gov/fdsys/pkg/BILLS - 112hr1540eh/pdf/BILLS 112hr1540eh.pdf>. U.S. HCFC Manufacturer Representatives. 2008 . Personal communications between ICF International and HCFC ma nufacturers, including AGC Chemicals, Honeywell, DuPont, Kivlan, Solvay, and York . February – March, 2008 . U.S. HCFC Manufacturer Representatives. 2009 . Personal communications between ICF International and HCFC ma nufacturers, including Halon Alternatives Research Corporation (HARC) and Honeywell . January- July

2009.The U.S Phaseout of HCFCs: Updated Projected Servicing Needs in the U.S. Air - Conditioning, Refrigeration, and Fire Suppression Sector s for 2015 to 2025

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March 2014 Page 58 U.S. HCFC Manufacturer Representatives. 2013 . Personal communications between EPA and refrigerant industry representatives, including Airgas, AHRI, The Alliance for Responsible Atmospheric Policy, Arkema, Com bes Investment Property, DuPont , HARDI, Honeywel l , Hudson, National , Polar Technologies and USA Refrigerants . March - July , 20 13. Verisae . 2009. Personal communication between Em ily Herzog, ICF International , and Ted Gartland, Verisae. May

2009. WM ATA . 2005 . Em ail correspondence between Lauren Flinn , ICF Consulting and Joan Lelacheur, Wa shington Metro Area Transit Authority . June 2005.